Restricted Jurisdictions

Circlworld is committed to operating responsibly within the laws and regulations of every jurisdiction we serve. As an operating platform with members in multiple countries, we must comply with international sanctions regimes, anti-money-laundering frameworks, and the specific regulatory requirements of each jurisdiction where we operate.

This page sets out the countries and regions where Circlworld is unable to offer services, and explains the reasoning. It is published in the interest of transparency, so that potential members and partners can understand our operating scope before engaging with us.

Who this page is for

If you are considering signing up for Circlworld, becoming a treasurer, or partnering with us as an Enterprise customer, please review this page to confirm that your country of residence (or operation) is not on our restricted list.

If your country is on the restricted list, our identity verification (KYC) providers will be unable to verify you, and you will not be able to complete the signup process. We do this proactively to avoid disappointment and to ensure compliance with the legal frameworks that govern our operations.

Restricted countries and regions

The following countries and regions are restricted. Members residing in these jurisdictions cannot use the Circlworld platform.

Comprehensive sanctions jurisdictions

These countries and regions are subject to comprehensive international sanctions. Circlworld cannot serve members resident in, or operating from, these jurisdictions:

• Cuba
• Iran (Islamic Republic of)
• North Korea (Democratic People's Republic of Korea)
• Syria
• The Crimea region of Ukraine
• The Donetsk and Luhansk regions of Ukraine
• Russia
• Belarus

Comprehensive sanctions apply to all financial services, not just specific products or activities. Our identity verification providers (Onfido, Smile ID, Persona, Sumsub) systematically reject verification attempts from these jurisdictions.

FATF high-risk jurisdictions

The Financial Action Task Force (FATF) maintains a public list of jurisdictions with strategic deficiencies in their anti-money-laundering and counter-terrorist-financing frameworks. Circlworld applies enhanced due diligence to applications from these jurisdictions and may not be able to serve all applicants.

As of the date of this page, FATF-monitored jurisdictions include:

• Myanmar (Burma)
• Democratic People's Republic of Korea

The current FATF list is updated periodically. We follow FATF guidance and update our position accordingly.

Jurisdictions pending expansion analysis

Beyond sanctioned jurisdictions, there are countries where Circlworld has not yet completed the regulatory analysis necessary to operate. We do not serve members in these jurisdictions while the analysis is incomplete.

Current operational scope:

• Active: Jamaica, United Kingdom
• Diaspora expansion (Year 1): Members in the Caribbean diaspora communities of the United Kingdom and (when expansion is complete) the United States
• Pending analysis: Trinidad & Tobago, Barbados, Guyana, Grenada, Saint Lucia, Antigua & Barbuda, Saint Vincent & the Grenadines, Dominica, Saint Kitts & Nevis, Belize, Bahamas, Haiti, Dominican Republic, Suriname, Cayman Islands, Turks & Caicos Islands, Bermuda, Anguilla, British Virgin Islands, Montserrat
• Pending analysis (broader expansion): Ghana, Nigeria, Kenya, South Africa, India, Bangladesh, the Philippines

If your country is in the "Pending analysis" group, we are working toward serving you but cannot do so yet. We will announce expansion as it becomes operationally and legally viable.

Other restrictions

In addition to the above, Circlworld may decline to serve specific individuals where:

• The applicant appears on a sanctions list (OFAC, HM Treasury, EU, UN Security Council, or equivalent)
• The applicant has been the subject of a confirmed Suspicious Transaction Report (in any jurisdiction)
• The applicant has been convicted of, or charged with, an offence involving dishonesty (fraud, theft, money laundering, etc.)
• The applicant's involvement would create a regulatory risk that Circlworld cannot mitigate

These individual restrictions apply regardless of the country of residence.

How this affects you

If your country is on the restricted list

You will not be able to complete identity verification (KYC) or create an active Circlworld account. Our verification providers will reject your application automatically.

We cannot make exceptions to sanctions regimes. We can sometimes consider applications from FATF-monitored jurisdictions on a case-by-case basis with enhanced due diligence.

If your country is in the "Pending analysis" group

Circlworld is not yet available in your country. We will publish updates when expansion becomes possible. You can register your interest at circlworld.com/expansion to be notified when service becomes available.

If you become subject to restriction during your membership

If, during your membership, your country of residence becomes subject to comprehensive sanctions, your account will be paused. We will work with you to wind down any active circle participation in compliance with applicable sanctions regulations.

If you become individually subject to sanctions (added to a sanctions list), your account will be paused immediately as required by law.

Why we publish this

International financial services platforms have an obligation under anti-money-laundering and counter-terrorist-financing regulations to know who they serve and to apply consistent risk-based controls. Publishing our restricted jurisdictions is part of meeting that obligation transparently.

This page also supports our banking partners and regulatory engagement. Partners and regulators reviewing Circlworld can see our clear posture on jurisdictional limits, which strengthens the partnership and regulatory relationships that make the platform viable.

How this list is updated

The list of restricted jurisdictions is reviewed and updated:

• Whenever international sanctions are imposed, lifted, or modified
• Quarterly to align with FATF updates
• When Circlworld expands operationally to additional jurisdictions
• When operational considerations require additional restrictions

We will give 30 days' notice before adding a previously unrestricted jurisdiction to the list (except where sanctions imposition requires immediate action).

The current version of this list is always available at this URL. The page header includes the date of the last update.

Questions or concerns

If you have questions about whether your country is restricted, or about how this affects you, please contact us at compliance@circlworld.com.

If you believe a restriction has been applied to you in error, you may raise this through our complaints process.

This page is part of Circlworld's legal and compliance framework. It is read together with the Terms of Service, the Privacy Notice, and the Acceptable Use Policy. It is updated periodically; the date of last update is shown above.