Restricted and Prohibited Jurisdictions: A Targeting Reference for IBs

You have a lead in a country you have never marketed to, and now you need to know fast whether promoting your partner broker there is a compliance problem or a business-as-usual one. The answer is never a single global list. It is a layered check: sanctions law, the broker's own license footprint, the payment rails available, and the platform rules of wherever you post content. Get any one layer wrong and you can lose your commission, your account, or worse.

This article gives you a working reference for how restricted jurisdictions actually function for an IB — not a static blacklist to memorize, but the categories of restriction and the questions to ask before you target a new country.

Three different kinds of "restricted" — don't conflate them

Most IBs think of restrictions as one list. In practice there are three separate, non-overlapping layers, and a country can sit in more than one at once.

1. Sanctions and legal prohibition. Countries under comprehensive sanctions regimes (historically Iran, North Korea, Syria, Cuba, and parts of the Russian financial sector under EU/UK/US sanctions programs) are off-limits for essentially any regulated financial business, IB promotion included. This is not a broker preference — it is law, enforced by bodies like the US Treasury's OFAC, the EU, and the UK's OFSI.
2. Regulatory jurisdiction mismatch. A broker licensed by one regulatory jurisdiction cannot lawfully solicit retail clients in a country where it holds no local authorization. A Vanuatu-licensed entity marketing hard into France is a licensing problem for the broker, and an exposure problem for the IB who ran the campaign.
3. Broker or platform business policy. Even where nothing is illegal, individual brokers exclude certain countries by internal risk policy — often the US, sometimes Japan, sometimes wherever their regulatory umbrella doesn't reach. Ad networks and social platforms add a fourth layer on top: their own advertising-policy restrictions on financial promotions, which can be stricter than the law.

Layer 1: sanctions — the hard floor

Sanctions lists are the one category where there is no judgment call. If a country or entity is on a comprehensive sanctions list, no compliance approval process changes that, and no broker's onboarding team can override it.

The practical reference points:

• OFAC Specially Designated Nationals (SDN) List and country programs (US) — comprehensive programs currently cover Iran, North Korea, Cuba, Syria, and specified regions/sectors of Russia and Belarus.
• EU and UK sanctions regimes — overlapping but not identical to the US list; always check both if you operate across US, EU, and UK audiences.
• FATF blacklist ("Call for Action") — as of mid-2026 this covers Iran, North Korea, and Myanmar. These are AML-deficiency designations, not sanctions per se, but they trigger the same practical effect: correspondent banks de-risk, and most regulated brokers refuse to onboard clients from these jurisdictions regardless of the client's individual circumstances.

Layer 2: the FATF grey list — a different kind of friction

Separate from the blacklist, FATF maintains a "grey list" of jurisdictions under increased monitoring for anti-money-laundering-aml deficiencies. As of the June 2026 plenary, that list runs to roughly 22 countries, with recent entries and exits reflecting ongoing FATF review cycles — the list changes multiple times a year, so treat any static number as a snapshot, not a fact to memorize.

Grey-listing does not make promotion illegal. It does mean:

• Brokers apply enhanced know-your-customer-kyc-for-ibs checks to clients from these countries, which slows onboarding and can raise your drop-off rate.
• Correspondent banking relationships tighten, which can delay deposits and withdrawals — a real friction point if your audience is deposit-sensitive.
• Some brokers voluntarily exclude grey-listed countries from marketing even though nothing legally requires it, purely to reduce their own AML workload.

Layer 3: the broker's actual license footprint

This is the layer IBs skip most often, and it is the one that creates real personal exposure. A broker being "regulated" tells you nothing about where it can legally accept clients — it tells you which regulator supervises it, and that regulator's authorization is bounded to specific markets. This is exactly the mechanic covered in territorial restrictions: a UK FCA license does not authorize soliciting in Germany, and an ASIC license does not authorize soliciting in Canada, even though both are respected, mainstream regulators.

Before you run a campaign into a new country, get answers to three questions from your partner manager, in writing:

1. Does the broker hold a license, passport, or explicit exemption to solicit retail clients in this specific country?
2. Is this country on the broker's own excluded-countries list in your IB agreement? Almost every partner agreement has one, and it is rarely identical to any public sanctions or FATF list.
3. If the broker is unregulated or relies on an offshore broker license, what happens to your commission if the country later gets added to their restricted list?

Worked example: the same broker, three different answers

Consider a broker regulated by CySEC in Cyprus, with an additional entity licensed offshore in the Bahamas, marketing to three regions:

• A reader in Germany: the CySEC license is passported under MiFID across the EEA, so soliciting in Germany is within scope — assuming the broker actually maintains that passport and hasn't let it lapse.
• A reader in the United States: neither the CySEC nor the Bahamas entity has CFTC/NFA authorization. US retail forex requires registration with US regulators specifically; soliciting US persons through either entity is prohibited regardless of how well-regulated the broker looks elsewhere.
• A reader in a FATF grey-listed country: legal, but expect the broker's Bahamas entity (not the CySEC one) to be the one actually accepting the client, with slower KYC and possibly different leverage terms — worth knowing before you set expectations with your audience.

The lesson: "this broker is well-regulated" is not a per-country answer. You need the per-country answer, every time you expand into a new market.

Mistakes that cost IBs their commission or their account

• Running the same ad creative into every country. Ad-platform financial-promotion policies (particularly for CFDs and binary options) vary by country independent of the broker's own license status — content acceptable in one market gets an account suspended in another.
• Trusting a broker's affiliate dashboard geography filter as the compliance answer. It is a targeting tool, not a legal opinion. Verify against the broker's actual terms.
• Assuming grey-list status means "avoid." Overreacting and dropping a legitimate market costs you revenue for no compliance benefit; the grey list is a monitoring signal, not a prohibition.
• Ignoring the marketing compliance angle on top of geography. A claim that's compliant in one regulator's jurisdiction (e.g., stating historical win rates a certain way) can be a violation under a different regulator's promotion rules for the same country.
• Not re-checking after onboarding. Restricted-country lists change. A country legal to promote to in January can be excluded by June if the broker loses a license or FATF re-lists it.

How to build a repeatable check

1. Screen the target country against current sanctions lists (OFAC, EU, UK) before any first campaign.
2. Confirm FATF status (blacklist vs grey list vs clear) and note it — grey list changes the onboarding experience you should set expectations for, not whether you can promote.
3. Request the broker's excluded-countries list in writing, dated, and re-request it quarterly.
4. Confirm the specific entity handling that country's clients and its license basis.
5. Check the ad platform or content platform's financial-promotion policy for that country separately from the legal check.
6. Log the check with a date, so if a dispute arises later you can show what you verified and when.

Where this fits with the rest of your compliance picture

Restricted-jurisdiction screening is one piece of a broader question — whether you personally need a license to operate as an IB at all in your home market. Geography restrictions apply to who you can market to; licensing requirements apply to whether you, as the promoter, need registration in your own country. Both matter, and they are evaluated separately.

For official reference points rather than secondhand summaries, go to the source: the FATF's own list of high-risk jurisdictions, the FCA's register to verify a broker's actual UK authorization scope, and OFAC's sanctions list search to check a specific country or entity directly.

The partner bridge

Restricted-jurisdiction rules are only useful once you know which brokers, exchanges, and prop firms you are actually evaluating. Revenika's partner glossary gives you the shared vocabulary — regulatory jurisdiction, offshore broker, compliance approval, and the rest — so that when you do sit down with a partner manager to ask the three questions above, you are asking them in terms both sides understand precisely.

Frequently Asked Questions

Can I lose my commission if a country I've been promoting to gets added to a restricted list?

Usually yes, for new business going forward, though most agreements grandfather clients already onboarded before the change. Read your IB agreement's amendment and grandfathering clauses specifically — this varies broker to broker and is rarely stated clearly in marketing materials.

Is the FATF grey list the same as a sanctions list?

No. FATF grey-listing flags AML-monitoring concerns and affects banking friction and broker onboarding speed; it does not itself make promotion illegal. Sanctions lists (OFAC, EU, UK) are legal prohibitions with civil and criminal penalties attached. Confusing the two leads IBs to either over-restrict themselves unnecessarily or under-restrict where it actually matters.

Does a broker's regulatory license automatically cover every country?

No. A license authorizes activity in the jurisdictions the regulator actually covers, sometimes extended by passporting arrangements (like MiFID within the EEA). Always confirm passporting status per country rather than assuming a well-known regulator's name means global coverage.

Who is responsible if I market into a restricted country by mistake — me or the broker?

Both can face consequences, but they are not identical. The broker risks its license and regulatory standing; you risk your IB agreement (clawback, termination) and, in serious cases, personal regulatory exposure depending on your own jurisdiction's rules on unlicensed solicitation. Neither party's risk cancels the other's — verify independently rather than assuming the broker's compliance team caught it.

How often should I re-check a country's status once I've started marketing there?

Quarterly at minimum, and immediately after any FATF plenary (three times a year) or any notice from your broker about updated terms. Sanctions changes can happen with no warning, so build the check into a recurring calendar reminder rather than a one-time task.

Conclusion

Restricted jurisdictions are not one list — they are four independent filters: sanctions law, FATF status, the broker's actual license footprint, and platform advertising policy. Treat each separately, request the broker's current excluded-countries list in writing, and re-verify on a schedule rather than trusting that yesterday's answer still holds. The IBs who get burned are rarely the ones who checked and got a nuanced answer; they're the ones who assumed one list covered everything.