Service Territories and Prohibited Jurisdictions Annex
Where the service is available from, which countries and territories are prohibited and how this is checked at sign-up and order.
In force from
1. Service territories
1.1. This annex (hereinafter: “Annex”) qualifies as the SERVICE TERRITORIES AND PROHIBITED JURISDICTIONS ANNEX under clauses 1.5 and 14.10 of the GENERAL TERMS AND CONDITIONS (hereinafter: “Terms”). Capitalised terms used in this Annex shall have the meanings ascribed to them in the Terms.
1.2. The Service is available to Merchants having their registered office and billing country in the following countries:
a) the Member States of the European Union;
b) the United Kingdom;
c) Switzerland;
d) Norway.
1.3. A country not listed in clause 1.2 does not belong to the service territories even if it is not included in clause 2. The scope of service territories is expanded by amending the Annex and publishing it with a new effective date.
1.4. A country under clause 1.2 does not provide availability if the Merchant is connected to a Prohibited Jurisdiction under clause 2 or clause 3.
1.5. The Provider checks availability in two stages: during registration, and prior to taking the Store live or concluding a subscription. Both checks cover the country code of the tax number, the registered office and the billing country. The Provider permits registration, taking the Store live or concluding a subscription if all three data fall within the scope of countries under clause 1.2, and none of them is connected to a Prohibited Jurisdiction under clause 2 or clause 3.
1.6. If the data under clause 1.5 are incomplete or contradictory, or if on the basis of obvious circumstances it arises that the Merchant may be subject to a restrictive measure or circumvents it, the Provider may suspend registration, going live or subscription until the conclusion of the case-by-case check, and may request verification from the Merchant pursuant to clause 4.6. The Provider does not maintain an exception-handling procedure.
2. Prohibited Jurisdictions
2.1. The Provider applies an operating regime stricter than the legal minimum. Any country and territory to which restrictive measures of the European Union relating to a country or territory apply qualifies as a Prohibited Jurisdiction, regardless of whether these prescribe a comprehensive economic prohibition or targeted measures. In respect of these jurisdictions, the Provider does not apply enhanced due diligence or an individual exception procedure.
2.2. The following countries qualify as Prohibited Jurisdictions, as of the verification date specified in clause 6.2:
| Country | Country code | EU legal basis |
|---|---|---|
| Afghanistan | AF | Council Regulation (EU) No 753/2011; Council Decision 2011/486/CFSP |
| Guinea-Bissau | GW | Council Regulation (EU) No 377/2012; Council Decision 2012/285/CFSP |
| Bosnia and Herzegovina | BA | Council Decision 2011/173/CFSP |
| Burundi | BI | Council Regulation (EU) 2015/1755; Council Decision (CFSP) 2015/1763 |
| South Sudan | SS | Council Regulation (EU) 2015/735; Council Decision (CFSP) 2015/740 |
| Belarus | BY | Council Regulation (EC) No 765/2006; Council Decision 2012/642/CFSP |
| Guatemala | GT | Council Regulation (EU) 2024/287; Council Decision (CFSP) 2024/254 |
| Guinea | GN | Council Regulation (EU) No 1284/2009; Council Decision 2010/638/CFSP |
| Haiti | HT | Council Regulation (EU) 2022/2309; Council Decision (CFSP) 2022/2319 |
| Iraq | IQ | Council Regulation (EC) No 1210/2003; Council Common Position 2003/495/CFSP |
| Iran | IR | Council Regulation (EU) No 267/2012; Council Decision 2010/413/CFSP; Council Regulation (EU) No 359/2011; Council Decision 2011/235/CFSP; Council Regulation (EU) 2023/1529; Council Decision (CFSP) 2023/1532 |
| Yemen | YE | Council Regulation (EU) No 1352/2014; Council Decision 2014/932/CFSP |
| China | CN | Madrid Declaration of the European Council of 27 June 1989 |
| Democratic People’s Republic of Korea (North Korea) | KP | Council Regulation (EU) 2017/1509; Council Decision (CFSP) 2016/849 |
| Democratic Republic of the Congo | CD | Council Regulation (EC) No 1183/2005; Council Decision 2010/788/CFSP |
| Central African Republic | CF | Council Regulation (EU) No 224/2014; Council Decision 2013/798/CFSP |
| Lebanon | LB | Council Regulation (EC) No 1412/2006; Council Regulation (EC) No 305/2006; Council Regulation (EU) 2021/1275; Council Decision (CFSP) 2021/1277 |
| Libya | LY | Council Regulation (EU) 2016/44; Council Decision (CFSP) 2015/1333 |
| Mali | ML | Council Regulation (EU) 2017/1770; Council Decision (CFSP) 2017/1775 |
| Myanmar | MM | Council Regulation (EU) No 401/2013; Council Decision 2013/184/CFSP |
| Moldova | MD | Council Regulation (EU) 2023/888; Council Decision (CFSP) 2023/891; Council Decision 2010/573/CFSP |
| Nicaragua | NI | Council Regulation (EU) 2019/1716; Council Decision (CFSP) 2019/1720 |
| Niger | NE | Council Regulation (EU) 2023/2406; Council Decision (CFSP) 2023/2287 |
| Russia | RU | Council Regulation (EU) No 833/2014; Council Decision 2014/512/CFSP; Council Regulation (EU) 2024/1485; Council Decision (CFSP) 2024/1484; Council Regulation (EU) 2024/2642; Council Decision (CFSP) 2024/2643 |
| Syria | SY | Council Regulation (EU) No 36/2012; Council Decision 2013/255/CFSP |
| Somalia | SO | Council Regulation (EU) No 356/2010; Council Decision 2010/231/CFSP |
| Sudan | SD | Council Regulation (EU) No 747/2014; Council Decision 2014/450/CFSP; Council Regulation (EU) 2023/2147; Council Decision (CFSP) 2023/2135 |
| Turkey | TR | Council Regulation (EU) 2019/1890; Council Decision (CFSP) 2019/1894 |
| Tunisia | TN | Council Regulation (EU) No 101/2011; Council Decision 2011/72/CFSP |
| Venezuela | VE | Council Regulation (EU) 2017/2063; Council Decision (CFSP) 2017/2074 |
| Zimbabwe | ZW | Council Regulation (EC) No 314/2004; Council Decision 2011/101/CFSP |
2.3. The following territories qualify as Prohibited Jurisdictions; their treatment is governed by clause 3:
| Territory | EU legal basis |
|---|---|
| Crimea | Council Regulation (EU) No 692/2014; Council Decision 2014/386/CFSP |
| Sevastopol | Council Regulation (EU) No 692/2014; Council Decision 2014/386/CFSP |
| Non-government controlled areas of the Donetsk oblast (Ukraine) | Council Regulation (EU) 2022/263; Council Decision (CFSP) 2022/266 |
| Non-government controlled areas of the Kherson oblast (Ukraine) | Council Regulation (EU) 2022/263; Council Decision (CFSP) 2022/266 |
| Non-government controlled areas of the Luhansk oblast (Ukraine) | Council Regulation (EU) 2022/263; Council Decision (CFSP) 2022/266 |
| Non-government controlled areas of the Zaporizhzhia oblast (Ukraine) | Council Regulation (EU) 2022/263; Council Decision (CFSP) 2022/266 |
2.4. The Provider shall reject the Order if the country code of the Merchant’s tax number, registered office or billing country is linked to a country under clause 2.2 or, pursuant to clause 3.2, to a territory under clause 2.3. Rejection and the suspension of performance of an existing contract shall be governed by clauses 4.6 and 14.12 of the Terms.
2.5. The Annex sets out the Provider’s operating regime and does not mean that the provision of the Service in the countries listed is prohibited by EU legislation in all cases. The fact that a country or territory is not listed in clause 2.2 or clause 2.3 does not mean that a Merchant from there or its owner is not subject to restrictive measures.
3. Handling of territorial regimes
3.1. In the case of the territories under clause 2.3, the country code is not decisive. The country code of Ukraine does not in itself qualify as a Prohibited Jurisdiction, and the code of another country or a registered office registered there does not preclude the application of clause 2.3.
3.2. A Merchant is linked to a territory under clause 2.3 if either its registered office, its place of business, or the actual place of use of the Service is located there. The Merchant makes its representation under clause 8.4.2 of the Terms extending to these circumstances as well, and may not use the Service in such territory, and may not make it accessible to persons in such territory.
3.3. The scope of non-government controlled areas may change. If the classification of the location concerned is doubtful, the Provider may request proof from the Merchant regarding the registered office, the place of business or the place of use, and may act pursuant to clause 14.12 of the Terms until the doubt is clarified. The Provider does not undertake an obligation to publish a settlement-level list.
3.4. Under clause 1.2, Ukraine does not belong to the service territories. This clause also applies to a Merchant registered in a country under clause 1.2.
4. Thematic lists and management of residual risk
4.1. The European Union applies the following thematic sanctions regimes. These are based on lists relating to specified persons and entities, therefore they are not country bans, and do not create a Prohibited Jurisdiction under clause 2:
a) measures against the proliferation and use of chemical weapons (Council Regulation (EU) 2018/1542; Council Decision (CFSP) 2018/1544);
b) measures against cyber-attacks threatening the Union or its Member States (Council Regulation (EU) 2019/796; Council Decision (CFSP) 2019/797);
c) measures against serious human rights violations and abuses (Council Regulation (EU) 2020/1998; Council Decision (CFSP) 2020/1999);
d) specific measures against terrorism (Council Regulation (EC) No 2580/2001; Council Common Position 2001/931/CFSP);
e) measures against persons supporting, facilitating or enabling violent acts by Hamas and the Palestinian Islamic Jihad (Council Regulation (EU) 2024/386; Council Decision (CFSP) 2024/385);
f) measures applied in respect of ISIL (Da’esh) and Al-Qaeda (Council Regulation (EC) No 881/2002; Council Decision (CFSP) 2016/1693).
4.2. The country and territorial exclusion under this Annex reduces, but does not eliminate, the risk arising from restrictive measures, and does not in itself ensure full compliance. A Merchant registered in a country under clause 1.2 may also be owned or controlled by a person subject to restrictive measures, and serving such a Merchant may be prohibited.
4.3. In accordance with its representation under clauses 8.4.3 and 14.11 of the Terms, the Merchant represents that
a) the Merchant is not included on the list of persons and entities designated under restrictive measures of the European Union;
b) to its knowledge, the Merchant’s representative, beneficial owner and the person exercising control over it are not included on these lists, and the Merchant is not directly, indirectly or jointly owned at least 50 per cent or otherwise controlled by such person; and
c) it does not use the Service to circumvent restrictive measures, in particular through an intermediary organisation in a third country or for the purpose of use in a Prohibited Jurisdiction.
4.4. The Merchant shall notify any change in the circumstances under clause 4.3 without delay in accordance with clause 14.11 of the Terms.
4.5. The Provider does not undertake an obligation for the individual, comprehensive manual screening or continuous ownership review of Merchants, their representatives and beneficial owners, and this Annex shall not be construed as such an undertaking.
4.6. If, on the basis of a name match, a discrepancy between the provided data, a differing billing country, an unusual payment route, the actual place of use or other obvious circumstance, it arises that the Merchant may be subject to a restrictive measure or may be circumventing it, the Provider may carry out an ad hoc check, may request corporate and ownership verification from the Merchant for this purpose, and may suspend the Service in accordance with clause 14.12 of the Terms. If the suspicion is confirmed, or the Merchant does not make the necessary verification available, the Provider may exercise extraordinary termination in accordance with clause 18.9 of the Terms.
5. Update procedure
5.1. The Provider monitors the status of restrictive regimes on the basis of the European Union Sanctions Map (EU Sanctions Map, www.sanctionsmap.eu). If the data on the map and the legal act published in the Official Journal of the European Union differ, the text of the Official Journal shall govern.
5.2. The Provider shall review the Annex monthly and, in addition, without delay if the European Union adopts new restrictive measures relating to a country or territory, or repeals existing such measures or amends their territorial scope.
5.3. Every published text of the Annex is identified exclusively by its full title and its effective date; it does not contain a version number. The availability of effective and archived versions shall be governed by clause 20.10 of the Terms; the version applicable to the Merchant is recorded in the Order Record.
5.4. For a new Order, the amended version of the Annex shall apply from its publication.
5.5. For amendments affecting an existing contract, clauses 18.2–18.4 of the Terms shall govern as follows:
a) if an amendment to the Annex is necessitated by a legal act of the European Union, the amendment may be brought into effect without a prior notice period pursuant to clause 18.4 of the Terms;
b) if, as a result of the amendment, the Merchant’s country or territory becomes a Prohibited Jurisdiction, the Provider may suspend the Service pursuant to clause 14.12 of the Terms, and may exercise extraordinary termination pursuant to clause 18.9(c) of the Terms; if performance is prohibited by law, the suspension may be applied without prior notice and without an additional period, without delay;
c) payment of fees during the period of suspension shall be governed by clause 14.13 of the Terms, and the consequences of the termination of the contract shall be governed by Chapter 18 of the Terms.
5.6. The deletion of a country or territory from clause 2 shall not in itself make the country or territory concerned a service territory; the scope of service territories is expanded pursuant to clause 1.3.
6. Sources and verification date
6.1. The Annex is based on the following sources:
a) EU Sanctions Map;
b) the Official Journal of the European Union (EUR-Lex), the legal acts specified in clauses 2 and 4;
c) the 2026 extension decisions: (CFSP) 2026/1767 (Lebanon), (CFSP) 2026/2197 (Burundi), (CFSP) 2026/2261 (Sudan), (CFSP) 2026/2277 (Niger), (CFSP) 2026/2317 (Guinea), (CFSP) 2026/2397 (Moldova).
6.2. Verification date: 31 October 2026.
