Blacklisted Jurisdictions Explained: Why the Other Side's Country Matters as Much as Yours
2026-10-08
A Payment Problem That Has Nothing to Do With the Amount
Most payment problems are about money. A fee turns out higher than expected, a transfer takes three days, a card hits its limit. There's another kind that shows up earlier and has nothing to do with the amount: the payment is stopped because of where the other side is.
Polydirection publishes a list of Prohibited Countries on its Blacklisted Jurisdictions page. At the time of writing, in October 2026, it has 104 entries. The page is short and blunt, and it's worth reading closely, because the wording covers more ground than most people assume.
What the Page Actually Says
The key sentence is this one: Polydirection "will not serve any person connected to Prohibited Countries, will not have any kind of business relationship with such persons, and will not process incoming or outgoing transactions related to Prohibited Countries."
Three separate rules are packed into it:
- Who can be a client. A person connected to a listed country won't be served.
- Who Polydirection does business with. No business relationship of any kind with such persons.
- Which payments go through. Transactions related to a listed country aren't processed, whichever way the money is moving.
The page also says the list "is fixed by Polydirection unilaterally and is subject to regular change." Keep that in mind. It's Polydirection's own list, and it moves.
It's Not Only About Your Own Passport
The usual assumption is that a blacklist is a question about the account holder. I'm not from one of those countries, so it doesn't concern me. The wording says otherwise. "Incoming or outgoing transactions related to Prohibited Countries" covers the people you pay and the people who pay you.
A few situations where this tends to come up:
- A freelancer in Spain takes on a new client whose company is registered in one of the listed countries. The work gets done, the invoice goes out, and the payment can't be accepted.
- An online shop finds a cheaper supplier abroad and sends a first prepayment. If the supplier's country is on the list, that transfer won't be processed.
- A company has a parent or a shareholder registered somewhere on the list. Day-to-day payments look perfectly ordinary, but "connected to" is broad wording, and a structure like that is exactly what it's written for.
In none of these cases did the account holder do anything wrong in the everyday sense. The other side of the payment simply sits in a jurisdiction Polydirection doesn't work with.
Some Entries People Don't Expect
Many names on the list are the ones you'd guess: Iran, North Korea, Syria, Russia, Afghanistan. Others catch people off guard, and those are the ones worth flagging.
- Popular company-registration locations. Panama, the Cayman Islands, Mauritius, Barbados and the Turks & Caicos Islands are all listed. They show up regularly in holding structures, which makes them relevant to business clients even when nobody involved actually lives there.
- Big outsourcing and freelance markets. Pakistan, Bangladesh, Sri Lanka and Nigeria are on the list. If you hire contractors or agencies there, payments to them fall under the same rule.
- Territories, not just countries. Guam, American Samoa, the US Virgin Islands and the US Minor Outlying Islands are listed separately, although the United States itself is not. Crimea and Western Sahara have their own entries too.
There's a map on the page, but small territories appear on it only as dots, and the page says the written lists are the authoritative version. If you're checking a specific place, read the list.
Why a Provider's List Is Longer Than the Public Ones
There are well-known public lists of high-risk jurisdictions, the FATF's being the best known. They're much shorter than 104 entries. That gap confuses people: this country isn't on any official blacklist, so why can't I send money there?
Because a payment provider's list isn't a copy of a public one. Polydirection's page gives two reasons for its list: "its legal and regulatory obligations" and "its high-quality level standards." In other words, the list reflects the provider's own obligations and its own view of risk. Two providers can end up with different lists, and a country missing from a public list tells you nothing about whether a particular provider will process payments there.
The List Changes, So Check It at the Right Moment
Since the list is "subject to regular change," checking it once when you open an account isn't enough. The moments that matter:
- Before you sign a new client or supplier. Look up their country, and for companies, where they're registered. Do it before the contract, not after the first invoice.
- Before you apply for an account for a company with a layered structure. If a shareholder, parent company or beneficial owner is connected to a listed country, raise it at the start.
- When a long-standing counterparty changes something. A client moving its billing to another entity, or a supplier switching to a bank in a different country, can change the answer.
It takes a minute. The alternative is finding out when a payment you were counting on doesn't arrive.
What Individual Review Can't Change
Polydirection looks at non-standard business cases individually: unusual ownership, a jurisdiction that needs a closer look, a business model that doesn't fit the standard form. (How that works is covered in "Declined Somewhere Else? What an Individual Review Can — and Can't — Change.")
It's worth being clear about the limits. Individual review is for cases that fall between the standard rules. It isn't a route around the Prohibited Countries list, and the page doesn't describe any exceptions to it.
That's also why it pays to ask early. If you can't tell whether something in your setup counts as "connected," have that conversation before you apply, or before you agree terms with a new partner.
A Short Checklist
- Read the current list on the Blacklisted Jurisdictions page, not a copy you saved months ago.
- Check both sides: where you are, and where the people you pay and get paid by are.
- For companies, check registration countries along the whole ownership chain, not just the operating company.
- Re-check when a counterparty changes country, entity or bank.
- If something looks borderline, ask before you apply or sign. Not after a payment has gone out.
