Jurisdiction Availability

Last updated: July 6, 2026

This page describes where ImplicitEx is intended to be available during limited launch and where access is restricted. The current public transfer interface is live on Polygon mainnet under a conservative soft-launch scope after hardened contract smoke verification.

Intended availability and restricted jurisdictions may change at any time based on law, sanctions, infrastructure availability, service-provider support, blockchain-network support, risk review, or business judgment. Users are responsible for complying with the laws that apply to them.

Policy Basis

Access to ImplicitEx may be restricted based on sanctions exposure, compliance risk, and operational judgment. This policy is informed by the following authoritative sources:

• U.S. Treasury OFAC — Sanctions Programs and Country Information. OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals. Sanctions may be comprehensive or selective and are implemented through blocking of assets and restrictions on trade and transactions.
• U.S. Treasury OFAC — Sanctions Compliance Guidance for the Virtual Currency Industry. OFAC's guidance for the virtual-currency industry confirms that sanctions obligations apply equally to virtual-currency transactions and traditional fiat transactions. Entities operating in this space must implement risk-based compliance programs.
• U.S. Treasury OFAC — Specially Designated Nationals and Blocked Persons List (SDN List). In addition to country-level restrictions, OFAC maintains a list of individuals, entities, and wallet addresses subject to sanctions regardless of location. Screening against sanctions lists may form part of a risk-based compliance and access-control program.
• FinCEN — Guidance on Virtual Currencies and Regulatory Responsibilities (FIN-2013-G001). FinCEN's guidance on convertible virtual currencies establishes the regulatory framework for administrators, exchangers, and users under the Bank Secrecy Act. Persons administering or exchanging virtual currency may be subject to MSB registration and AML program requirements.
• FATF — High-Risk Jurisdictions Subject to a Call for Action and Jurisdictions Under Increased Monitoring. The Financial Action Task Force publishes regularly updated lists identifying jurisdictions with strategic deficiencies in their anti-money-laundering and counter-terrorist-financing frameworks. These publications may be used as a secondary risk indicator when evaluating jurisdictional exposure and operational risk.

The restricted jurisdictions and persons listed below reflect this framework. Access may be restricted or discontinued at any time based on changes to sanctions programs, risk assessment, or platform policy. This page does not constitute a representation that ImplicitEx is legally permitted to operate in any specific jurisdiction; users are responsible for determining whether their use complies with the laws that apply to them.

Restricted by Platform Policy

ImplicitEx does not intend to support use by any person or entity that is located in, organized in, ordinarily resident in, controlled from, or acting on behalf of any restricted jurisdiction, sanctioned region, blocked person, or prohibited party.

The restricted list is intentionally conservative. It includes territory-wide sanctions and additional jurisdictions that ImplicitEx has chosen not to support for MVP risk-control reasons.

Intended MVP Availability

Subject to the restrictions above, ImplicitEx intends to limit MVP availability to the following jurisdictions. If a jurisdiction is not listed here, it should be treated as not supported unless ImplicitEx expressly adds it later.

Compliance Review

ImplicitEx may block, pause, refuse, or discontinue access where it believes use may violate sanctions, anti-money-laundering rules, counter-terrorist-financing rules, export controls, local law, platform policy, or security requirements.

This page is not legal advice and does not replace a user's responsibility to understand and follow the laws that apply to their own location, citizenship, organization, wallet, transaction, and counterparty.

References

1. U.S. Department of the Treasury, Office of Foreign Assets Control — Sanctions Programs and Country Information
2. U.S. Department of the Treasury, Office of Foreign Assets Control — Sanctions Compliance Guidance for the Virtual Currency Industry (PDF)
3. U.S. Department of the Treasury, Office of Foreign Assets Control — Sanctions List Search (SDN List)
4. Financial Crimes Enforcement Network — Guidance on Virtual Currencies and Regulatory Responsibilities (FIN-2013-G001)
5. Financial Action Task Force — High-Risk Jurisdictions Subject to a Call for Action