The country list is the most consequential product decision a trading firm makes, and it is usually made in an afternoon. Someone opens three competitor sites, takes the intersection of their restricted lists, and ships it. Six months later the firm discovers that its acquirer will not settle transactions from half of those markets and that a supervisor in a fourth has written to ask under what authority it accepted its residents.
The list is not one decision. It is four independent tests, and a country has to pass all four before it belongs on the accepted side.
Test one: does your licence reach that person
Financial services authorisation is territorial. A licence permits an activity in a place, for a defined client type. Serving a resident of another country is a question for that other country's law, not for your regulator's rulebook.
Three patterns exist. Some markets require local authorisation or a local branch before any solicitation. Some allow cross-border service from a recognised regime, either through passporting inside a bloc or through a third-country recognition path with conditions attached, which is the territory covered in third country firms and the EU. And some do not regulate inbound retail derivatives at all, which is not the same as permitting them.
Reverse solicitation exists in several regimes and is narrower than the industry pretends. It covers a client who approaches the firm entirely on their own initiative, and in most readings it is destroyed by any marketing directed at that market, including a translated website or a local payment method. Building a business model on it does not work, for reasons set out in reverse solicitation.
Test two: sanctions and financial crime
This test is binary and it overrides commercial judgement. Country-wide sanctions programmes prohibit dealing with certain territories and with listed persons anywhere, and the obligation follows your banking relationships and your currency of settlement as well as your own registration. USD flows bring US nexus into the analysis. EUR flows bring EU measures. The mechanics are in sanctions screening basics.
Separately, jurisdictions under increased monitoring by the Financial Action Task Force attract enhanced due diligence from your bank, your PSP and your correspondent chain, whether or not you would otherwise restrict them. The practical effect is described in FATF grey list impact: not a prohibition, but a cost and friction level that can make a market uneconomic.
Sanctions and licensing analysis is legal work specific to your entity, your currencies and your banking chain. Treat this article as a description of the tests, not as clearance for any country. Get written advice before you open or close a market.
Test three: can money actually move
A country can be legally acceptable and commercially impossible. Card acquiring depends on issuer behaviour by country, and approval rates in some markets sit low enough that the marketing spend never recovers. Cross-border card transactions carry higher interchange and higher scrutiny, and a concentration of high-risk geographies in a merchant's mix is exactly what underwriting looks for.
Then there are capital controls and local rules that make outbound payments to a foreign trading firm difficult or prohibited for residents, which produces failed deposits, third-party payments and a rise in disputes. Payment refusals by country and BIN country mismatches cover the patterns that trigger reviews.
The payout side is the half firms forget. Accepting deposits from a market you cannot pay back into is a complaint generator and, for a prop firm, a reputational event that plays out publicly.
Test four: can you market there
If ad platforms require authorisation in a country before financial adverts run, an unlicensed firm cannot acquire clients there through paid channels. That is a distribution fact, not a legal one, and it decides whether a market is worth opening. Some firms discover their chosen jurisdiction supports neither their bank nor their advertising, which leaves organic and affiliate traffic, and affiliates in a market you cannot legally solicit is the worst of both.
How to sequence the decision
| Test | Question | Failure mode |
|---|---|---|
| Authorisation | Does any regime let us serve this resident? | Regulator letter, public warning, forced exit |
| Financial crime | Sanctions exposure, FATF status, PEP density | Frozen funds, bank exit, criminal risk |
| Payments | Will deposits approve and payouts settle? | Declines, disputes, reserves, PSP termination |
| Distribution | Can we advertise legally and technically? | Ad account restriction, no viable acquisition |
Run them in that order, because a failure at test one makes the rest irrelevant. Record the outcome per country with a date and the reason, and review it on a schedule. Regulatory positions move, and a list assembled two years ago is a liability rather than a policy.
Where the entity sits changes the answer
The country list and the corporate structure are the same decision seen twice. A UAE entity, for example, opens different banking and different markets than a Caribbean company with identical shareholders, which is one reason firms that plan to serve the Gulf and Asia look at a base such as Dubai before they choose a licence. Two-entity structures let a firm serve a regulated market through one company and other markets through another, with the split covered in two entity broker structures.
Then enforce it
A policy that lives in a document is not a control. The accepted-country list has to be enforced at registration, at document verification, at deposit and at login, with the residency determination based on verified evidence rather than a self-declared dropdown. Firms running the Broker CRM hold one country policy that the portal, the onboarding flow and the payment routing all read, so a country closed on Monday is closed everywhere on Monday.
"A country you cannot pay back into is not a market. It is a complaint you have not received yet."
— Alex Onta, Executive Director, SINGUARD
Key Takeaways
- A country belongs on the accepted list only after passing four separate tests: authorisation, financial crime, payments and distribution.
- Reverse solicitation is narrow and is generally lost the moment you direct any marketing at that market, so it cannot be a business model.
- Sanctions exposure follows your settlement currency and your banking chain, not only your place of registration.
- The list is worthless unless it is enforced at registration, verification, deposit and payout from a single source that every system reads.
Frequently Asked Questions
Can we accept a client from a country we are not licensed in if they find us themselves?
Some regimes recognise a narrow reverse solicitation exemption, but it usually requires that the client approached you entirely on their own initiative and that you did nothing to promote to that market. A translated site, local currency pricing or local payment methods tend to defeat it. It is a defence in specific cases, not a strategy.
Should our restricted list match our competitors?
No. Their list reflects their licence, their bank, their acquirer and their appetite. Copying it imports decisions that may be wrong for you in both directions, leaving markets open that your payments cannot support and closing markets you could serve properly.
How often should the country list be reviewed?
On a fixed schedule and on every trigger event: a sanctions change, a FATF plenary update, a new regulator warning, an acquirer notice or a licence change. Record each decision with a date and a reason so you can show why a country was open on a given day.
About the Author
Alex Onta is an Executive Director at SINGUARD. He built eTrader, the terminal, the mobile apps, eTrader Broker, Copytrading, Business and Community, along with the worldwide clustered-server infrastructure it all runs on, with his brother Roman Onta helping on the design, and he leads that division today. Together with Roman he builds the Prop Firm CRM, the Broker CRM, Scalegram and CopySignals, and the two of them carry worldwide compliance, payment processing and international business structuring side by side. He lives and works in Dubai for most of the year. Meet the executive duo leading Singuard's five divisions.