Restricted and sanctioned countries

1. Why we publish this page

One IBC Limited holds Hong Kong TCSP licence TC001305. Hong Kong law requires us to check every client against sanctions lists and to apply extra checks where the risk is higher.

This page lists the international lists we use as of September 2026 and explains how we treat clients connected with the countries on them. It was last reviewed on 27 September 2026.

Lists change several times a year. We review this page after each FATF plenary (February, June and October) and after each EU update. The dated official source is linked under each list.

2. FATF high-risk jurisdictions subject to a call for action

As of the FATF statement of 19 June 2026, the FATF calls on all countries to apply countermeasures to the Democratic People's Republic of Korea (DPRK) and Iran.

For Myanmar, the FATF calls for enhanced due diligence proportionate to the risk, not countermeasures.

This list is often called the "black list". It did not change at the June 2026 plenary.

3. FATF jurisdictions under increased monitoring

As of 19 June 2026, 22 jurisdictions are under increased monitoring, often called the "grey list": Angola, Bolivia, Bosnia and Herzegovina, Bulgaria, Cameroon, Côte d'Ivoire, the Democratic Republic of the Congo, Haiti, Iraq, Kenya, Kuwait, Lao PDR, Lebanon, Monaco, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, the Virgin Islands (UK) and Yemen.

Bosnia and Herzegovina and Iraq were added in June 2026. Algeria and Namibia were removed.

The FATF says it does not call for enhanced due diligence on these jurisdictions and does not want whole groups of customers cut off. It asks countries and firms to take the listing into account in their risk assessment. We do that case by case.

4. EU list of high-risk third countries for anti-money laundering

Firms in the EU must apply enhanced due diligence to business involving these countries. The list is in Delegated Regulation (EU) 2016/1675, last amended by Delegated Regulations (EU) 2026/46 and 2026/83, in force since 29 January 2026.

Countries with an FATF action plan: Afghanistan, Algeria, Angola, Bolivia, the British Virgin Islands, Cameroon, Côte d'Ivoire, the Democratic Republic of the Congo, Haiti, Kenya, Laos, Lebanon, Monaco, Myanmar, Namibia, Nepal, South Sudan, Syria, Trinidad and Tobago, Vanuatu, Venezuela, Vietnam and Yemen.

Countries named in FATF public statements: Iran and the DPRK. Country with suspended FATF membership: the Russian Federation.

The EU list does not always match the FATF list on the same day. This matters to you because EU banks and our licensed local partners in the EU must apply the EU list.

5. EU list of non-cooperative jurisdictions for tax purposes

As of the Council update of 17 February 2026, Annex I lists 10 jurisdictions: American Samoa, Anguilla, Guam, Palau, Panama, the Russian Federation, the Turks and Caicos Islands, the US Virgin Islands, Vanuatu and Viet Nam.

Viet Nam and the Turks and Caicos Islands were added in February 2026. Fiji, Samoa and Trinidad and Tobago were removed.

This is a tax list, not a sanctions list. EU countries apply defensive tax and reporting measures to it, and some banks apply extra checks. We tell you before you pay if a listing is likely to affect your company.

6. UN Security Council sanctions implemented in Hong Kong

Hong Kong implements UN Security Council sanctions through regulations made under the United Nations Sanctions Ordinance (Cap. 537). Terrorist designations are implemented under the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575). Services linked to weapons of mass destruction are controlled under Cap. 526.

As of 28 August 2026, the Hong Kong Government publishes targeted financial sanctions lists for these UN regimes: Afghanistan, the Central African Republic, the Democratic Republic of the Congo, the DPRK, Guinea-Bissau, Haiti, ISIL (Da'esh) and Al-Qaida, Libya, Somalia, South Sudan, Sudan and Yemen. Other UN measures, such as arms embargoes, also apply to Iran, Iraq and Lebanon.

It is an offence in Hong Kong to make funds or economic resources available to a designated person without a licence. We will not act for a designated person or for a company they own or control.

7. US, UK and EU sanctions

The United States (OFAC), the United Kingdom (OFSI and FCDO) and the European Union run their own sanctions programmes. Some go further than UN sanctions, for example on Russia, Belarus, Cuba and occupied regions of Ukraine.

Hong Kong law does not normally require us to apply other countries' sanctions. The Companies Registry expects licensees that operate internationally to understand them and act where they affect the business. Our banks, payment providers and local providers in the US, UK and EU must follow them, so in practice they affect whether we can act for you.

We screen every client, director, shareholder and beneficial owner against sanctions lists before we act, when the lists change and during the relationship. Banks and partners abroad apply their own sanctions, and we cannot act where they cannot.

8. How we treat clients connected with these countries

A client is "connected" with a country if the client, a director, shareholder or beneficial owner, or the source of funds or main business, is a national or resident of it, is incorporated there, or operates there.

The rules below are our policy. Each case is decided by our compliance staff, not by software alone.

• We refuse: anyone designated under UN sanctions implemented in Hong Kong, and any company they own or control.
• We refuse: clients connected with the DPRK or Iran, where the FATF calls for countermeasures.
• We refuse: business involving a territory under comprehensive sanctions where our banks or licensed local partners cannot act.
• Enhanced due diligence, risk-based: clients connected with Myanmar, with any jurisdiction on the FATF grey list or the EU high-risk list, or with a jurisdiction on the EU tax list. Vietnam is on all three. We ask for more information about ownership, source of funds and source of wealth, and senior management approves the file.
• We may decline any application where we cannot manage the risk, where a bank or local partner will not act, or where the information we receive is incomplete. We do not always give a reason.

9. What this means for you

If you are connected with a listed country, you can still contact us. Tell us early, so we can say whether we can help and what extra documents we will need.

We do not take a final decision on your nationality or country alone. We look at the whole file.

If we cannot accept you after you have paid, we refund what you paid under our Refund policy, as far as the law allows. Where a sanctions law requires funds to be frozen or reported, we must follow the law first.