Legal

Prohibited Countries and Activities Policy

A summary of the jurisdictions, business types, and client categories that are ineligible for, or subject to enhanced due diligence in connection with, Emanita's services.

Version 1.0Effective Date: January 2026Applicable Jurisdiction: Canada

Emanita Payments Limited ("Emanita") is a Money Services Business registered with FINTRAC. As part of our Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) compliance programme, we maintain a risk-based framework that determines which jurisdictions, business types, and client categories are ineligible for our services (Prohibited) or eligible only subject to Enhanced Due Diligence (Restricted). This page summarises that framework for our clients and prospective clients.

This page is a client-facing summary of our internal Prohibited Countries and Prohibited Activities / Client Acceptance Policy. Our internal policy contains additional governance, approval, and monitoring detail used by our compliance team and is not published externally. The classifications below may be updated at any time without prior notice, particularly following FATF Plenary updates (February, June, October) or changes to Canadian sanctions.

1. Basis for Classification

Emanita's country and activity classifications reflect Canada's economic sanctions legislation (administered by Global Affairs Canada under the United Nations Act, Special Economic Measures Act, Justice for Victims of Corrupt Foreign Officials Act, and Freezing Assets of Corrupt Foreign Officials Act), FINTRAC Ministerial Directives, Financial Action Task Force (FATF) Blacklist and Grey List designations, and Emanita's own risk appetite as a regulated Money Services Business.

2. Prohibited Countries

Emanita will not establish or maintain a business relationship with any client, ultimate beneficial owner, director, authorised signatory, or counterparty that is located in, incorporated in, operating from, or that presents a material connection to, any of the following jurisdictions. This restriction is absolute and applies without exception, other than the limited case described in Section 5.

AfghanistanBelarusCentral African RepublicChinaCubaDemocratic People’s Republic of Korea (North Korea)Democratic Republic of the CongoGuatemalaHaitiIranIraqLaosLebanonLibyaMaliMoldovaMyanmar (Burma)NicaraguaRussiaSahrawi Arab Democratic RepublicSomaliaSomalilandSouth OssetiaSouth SudanSri LankaSudanSyriaUkraine – Russian-occupied regions (Crimea, Donetsk, Luhansk, Zaporizhzhia, Kherson)VenezuelaYemenZimbabwe

This list is updated as Canadian sanctions are amended by Global Affairs Canada and following each FATF Plenary. The definitive source for Canadian sanctions is the Consolidated Canadian Autonomous Sanctions List.

3. Restricted Countries (Enhanced Due Diligence)

Emanita may establish or maintain a business relationship with clients connected to the following jurisdictions, but only where Enhanced Due Diligence (EDD) is completed and the resulting risk assessment is approved by our compliance team. EDD may include additional identity verification, proof of address, source of funds and wealth documentation, beneficial ownership attestations, and enhanced ongoing monitoring.

AngolaBahrainBangladeshBoliviaBosnia and HerzegovinaBulgariaBurkina FasoCambodiaCameroonCayman IslandsColombiaCôte d’IvoireDominican RepublicEgyptEthiopiaGhanaGuineaGuinea-BissauGuyanaHong KongIsrael / Palestinian TerritoriesJamaicaJordanKazakhstanKenyaKosovoKuwaitKyrgyzstanLiberiaMacedonia (North Macedonia)MalawiMauritiusMonacoMoroccoMozambiqueNepalNigeriaOmanPakistanPanamaPapua New GuineaPhilippinesQatarSaudi ArabiaSenegalSerbiaSeychellesSint MaartenSouth AfricaTanzaniaTogoTrinidad and TobagoTunisiaTurkeyTurkmenistanTurks and Caicos IslandsUgandaUkraine – unoccupied regionsVanuatuVietnamVirgin Islands (UK)Virgin Islands (US)Zambia

4. Clients and Beneficial Owners Connected to Prohibited Countries

Business entities and individuals resident, incorporated, or operating in a Prohibited country will not be onboarded under any circumstances. An ultimate beneficial owner who originates from a Prohibited country (for example, holds citizenship of that country but is not currently resident there) may, on an exceptional and strictly limited basis, be considered only where Emanita determines that the beneficial owner is not subject to sanctions, does not reside in a Prohibited country, and that no funds originate from or are destined for a Prohibited country, following Enhanced Due Diligence and written compliance approval.

5. Prohibited Business Types and Activities

Emanita will not establish or maintain a business relationship with any entity whose primary business activity falls within one of the following categories, regardless of jurisdiction, licensing status, or the size of the proposed relationship. This list is not exhaustive; Emanita may classify additional business types as Prohibited based on its assessment of financial crime or reputational risk.

Adult content and escort servicesArms, defence, and weaponsBearer share companiesBinary options trading platformsUnregulated cannabisChain letters and pyramid schemesCheque cashing servicesCounterfeit and replica goodsUnregulated crowdfunding platformsCyberlockers and unauthorised file sharingThird-party debt collection and consolidationIllicit drugs and drug paraphernaliaUnregulated environmental/carbon credit schemesForeclosure and mortgage modification servicesFortune telling and psychic servicesUnlicensed gambling, betting, lotteries, and casinosGrant assistance programsIllegal businesses and shell banksUnregulated investment programsMail order bride servicesNuclear power industryOffshore trusts in weak AML jurisdictionsPawnbrokersPayday lending servicesUnregulated or illicit pharmaceuticalsUnregulated precious metals and stones dealingPrivacy coins (e.g., Monero, Zcash, Dash)Unregistered religious organisationsShell entitiesTimeshare businessesTobacco productsTravel agents/services to sanctioned jurisdictionsUnlicensed securities dealers and brokersWildlife tradingExtended warranty businessesClients without a verified bank account

6. Restricted Business Types (Enhanced Due Diligence)

Emanita may provide services to entities in the following categories, but only where the entity undergoes Enhanced Due Diligence, holds applicable jurisdictional licences, and is approved by our compliance team prior to onboarding.

Aerospace and aviationAirlines and travelAuction servicesLicensed and regulated cannabisChemicalsConstructionRegulated dating servicesEducational programsLicensed financial institutionsLicensed gaming and gamblingGovernment contractorsHolding companiesRegulated investment and commodities brokersMarketing companiesMining and mineral extractionOther licensed Money Services BusinessesRegulated pharmaceuticalsRegulated precious metals dealingLicensed securities dealers and brokersUsed car dealershipsLicensed virtual currency businessesVitamins and herbal remedies

7. Client Acceptance and Ongoing Monitoring

All prospective clients are screened for geographic and industry risk before an application is progressed. Clients presenting a Prohibited country or Prohibited business connection are declined without exception. Clients presenting a Restricted connection may proceed only after Enhanced Due Diligence and documented compliance approval. Country and industry classifications, and the resulting client risk ratings, are reassessed on an ongoing basis and following material changes such as a change in beneficial ownership, a change in a client's registered address or business activities, or an update to Canadian sanctions or FATF designations.

8. Review and Updates

Emanita reviews its country classifications following each FATF Plenary (February, June, October) and upon any material change to Canadian sanctions, and reviews this Policy in full at least annually. Because these classifications change periodically, clients should confirm current eligibility with Emanita before initiating an application if in doubt.

9. Contact

Questions about this Policy or a specific eligibility determination can be directed to our compliance team at info@emanitaglobal.com.