Prohibited Activities & Jurisdictions

Prohibited Jurisdictions

Echlon does not provide services to users located in, establishing residency in, incorporated in, or operating from the following jurisdictions. These jurisdictions are subject to comprehensive or targeted U.S. OFAC sanctions programs, United Nations sanctions, or are prohibited by all of Echlon's regulated financial partners. Users from these jurisdictions are geo-blocked and denied platform access.

Jurisdictions not listed in Section 2 below, and not appearing here, are not currently supported by Echlon. The Compliance Officer maintains full discretion to update this prohibited list dynamically at any time based on sanctions designations, regulatory guidance, or partner requirements.

Supported Jurisdictions & Risk Classification

Echlon classifies supported jurisdictions into three risk tiers, determined using a risk-based methodology considering FATF evaluations, Basel AML Index scores, Know Your Country risk assessments, sanctions exposure, AML/CFT framework effectiveness, corruption and transparency indicators, geopolitical considerations, and risk assessments performed by Echlon's banking and payment partners. Users located in or associated with High Risk jurisdictions are subject to Enhanced Due Diligence ("EDD"), including additional identity verification, source of funds and source of wealth documentation, and ongoing monitoring; Medium Risk jurisdictions may also be subject to EDD at the Compliance Officer's discretion. Service availability in these jurisdictions may be limited depending on partner coverage. Jurisdictions not listed in any tier below are not currently supported by Echlon.

Jurisdiction risk classifications are reviewed periodically and may be updated by the Compliance Officer at any time based on FATF advisories and public statements, regulatory guidance, banking/payment partner risk assessments, or internal risk assessments.

Sanctioned Persons and Entities

Echlon does not provide services to individuals or entities designated on applicable sanctions lists, including the OFAC SDN and Consolidated Sanctions Lists, the UN Consolidated Sanctions List, the UK HM Treasury (OFSI) consolidated sanctions list, and the EU consolidated financial sanctions list. All users are screened at onboarding and on an ongoing basis. Digital asset wallet addresses are screened against sanctioned address databases.

Prohibited Activities

Echlon does not support accounts or transactions involving the following activities:

• Shell banks or entities without verifiable operations or transparent beneficial ownership
• Unlicensed money service businesses, remittance agents, exchange houses, or money transfer agents
• Securities broker-dealers, initial coin offerings (ICOs), and market manipulation or fraud
• Multi-level marketing (MLM) or pyramid schemes
• Weapons, arms, ammunition, explosives, or defense manufacturing and distribution
• Cannabis and controlled substances where prohibited by applicable law
• Darknet or Tor-based marketplaces
• Counterfeit, fraudulent, or IP-infringing goods and services
• Money laundering, terrorist financing, proliferation financing, or sanctions evasion
• Transactions involving sanctioned parties or wallets flagged as severe risk
• Identity fraud, fictitious accounts, or structures designed to obscure beneficial ownership
• Predatory lending, debt settlement, or non-compliant financial products
• Activity promoting hate, violence, terrorism, or discrimination
• Unauthorised data harvesting, sale, or consumer privacy violations

High-Risk Industries

The following industries are not prohibited but require Enhanced Due Diligence, including additional documentation and ongoing monitoring. Users in these sectors should expect longer onboarding timelines.

• Licensed gambling, gaming, casinos, and betting operations
• Adult content and entertainment platforms (where legal and licensed)
• Precious metals, gemstones, jewelry, art, antiques, and high-value goods trading
• Mining, extractive industries, and oil and gas
• Construction and real estate development
• Professional services acting in a financial intermediary capacity (lawyers, accountants, notaries)
• Licensed money services and currency exchange providers
• Import/export and logistics involving high-risk jurisdictions
• Non-profit organisations (NGOs and NPOs)
• Politically Exposed Persons (PEPs) and related parties
• Electronics and luxury goods trading

Enforcement

Echlon enforces jurisdictional and activity restrictions through IP monitoring, geolocation checks, sanctions screening, identity verification, blockchain analytics, and other compliance controls. Users may not circumvent these controls through VPNs, proxies, or other means. Violations may result in immediate account suspension, termination, and reporting to the appropriate authorities.

Service Availability

Availability of specific services — including payment corridors, currencies, card programs, and treasury products — varies by jurisdiction, partner coverage, and regulatory requirements. Echlon does not represent that the Services are available in every jurisdiction and may restrict access where legal, regulatory, or compliance risk exists.

Updates

Echlon may update this document at any time in response to changes in sanctions frameworks, FATF advisories and public statements, regulatory guidance, or partner requirements. If a jurisdiction becomes restricted, Echlon may immediately suspend access for affected users.

Contact

Echlon Ltd · British Virgin Islands
Compliance: [email protected] · General: [email protected]

Official sources

External sites referenced in this document. Echlon does not control their content or availability.

• Financial Action Task Force (FATF) — including high-risk jurisdictions monitoring
• U.S. Treasury — Office of Foreign Assets Control (OFAC) — SDN and consolidated sanctions information
• United Nations — Security Council Consolidated List
• UK — Office of Financial Sanctions Implementation (OFSI) consolidated list
• European Union — financial sanctions