LEGAL

Restricted Jurisdictions Policy

This Policy explains where Playto does not operate, which jurisdictions require enhanced review, and how sanctions and geographic risk affect accounts and transactions.

DATEJuly 14, 2026
BLOCKEDListed blocked jurisdictions and regions are not supported under the current policy.
ENHANCED REVIEWHigher-risk jurisdictions may require additional review before approval.
SUPPORTJurisdiction questions: support@playto.so

This Restricted Jurisdictions Policy ("Policy") describes geographic restrictions that apply to Playto, Inc., a Delaware corporation at 8 The Green, Ste R, Dover, DE 19901, United States ("Playto", "we", "us" or "our"). It applies to Service Partners, Buyers, transactions, payouts and other use of Playto to the extent incorporated into the applicable agreement.

This Policy supplements the Acceptable Use & Restricted Businesses Policy, Service Partner Terms and Buyer Terms & Conditions. A geographic restriction can apply even where the underlying professional service would otherwise be permitted.

Playto's internal availability policy may be broader than the restrictions imposed by any one sanctions, regulatory or external risk list. Inclusion in Playto's Blocked list does not mean that every person or transaction connected with that jurisdiction is independently prohibited by law; it means Playto does not support that jurisdiction under its current operating policy.

Playto uses three geographic treatment categories:

  • Blocked jurisdictions: jurisdictions or regions that Playto does not support under its current operating policy.
  • Enhanced Review jurisdictions: jurisdictions that are not automatically prohibited solely because of location, but that may require additional information, screening, approval, limits or other proportionate controls.
  • Other jurisdictions: jurisdictions not listed in either category. Absence from a list does not guarantee availability.

Geographic eligibility is only one part of the review. A transaction can still be prohibited or restricted because of a sanctioned person, ownership, the nature of the Service, the Buyer or beneficiary, the payment route, the payout destination, applicable law or another material risk factor.

Playto does not currently onboard Service Partners located in, ordinarily resident in, or primarily operating from the following jurisdictions, and does not knowingly support Buyer transactions, Service Orders or payouts where one of these jurisdictions is a material part of the transaction:

  • Afghanistan
  • Belarus
  • Burundi
  • Central African Republic
  • Cuba
  • Democratic Republic of the Congo
  • Eritrea
  • Iran
  • Iraq
  • Lebanon
  • Libya
  • Mali
  • Myanmar
  • Nicaragua
  • North Korea
  • Palestinian Territories
  • Russia
  • Somalia
  • South Sudan
  • Sudan
  • Syria
  • Ukraine
  • Venezuela
  • Yemen
  • Zimbabwe

This is a Playto operating and risk policy. Some entries reflect sanctions or external financial-crime risk; others reflect Playto's current banking, payment, underwriting, geographic or operational limits. Inclusion does not mean that every person or transaction connected with the jurisdiction is independently prohibited by law.

Blocked status is not an invitation to seek a transaction-by-transaction exception. Playto will support a jurisdiction only after Playto formally changes the applicable policy or expressly approves a lawful exception through its authorized legal and compliance process.

In addition to the country and territory restrictions above, Playto does not support transactions, businesses or services involving the following regions where applicable restrictions remain in force:

  • Crimea
  • Donetsk People's Republic / sanctioned portions of Donetsk
  • Luhansk People's Republic / sanctioned portions of Luhansk

A regional restriction applies based on the actual location, recipient, performance, ownership, destination or other relevant transaction facts. Using a mailing address, intermediary or payment account outside the restricted region does not change the underlying location.

The following jurisdictions are not automatically blocked under Playto's current policy, but may be subject to enhanced review:

  • Angola
  • Bolivia
  • Bosnia and Herzegovina
  • Bulgaria
  • Cameroon
  • Côte d'Ivoire
  • Haiti
  • Kenya
  • Kuwait
  • Laos
  • Monaco
  • Nepal
  • Papua New Guinea
  • Vietnam
  • British Virgin Islands

Presence on this list does not mean a business or transaction is presumed unlawful, suspicious or unacceptable. Playto applies a risk-based assessment to the actual business, ownership, Service, Buyer relationship and transaction.

Enhanced review may result in approval, approval with conditions, additional monitoring, transaction limits, delayed onboarding or rejection. It is not a promise that every applicant from an Enhanced Review jurisdiction can be supported.

Depending on the facts, Playto may request additional information reasonably relevant to the risk assessment, including:

  • business registration, operating address and ownership information;
  • identity and authority of relevant representatives;
  • the nature of the professional Service and the Buyer relationship;
  • source of funds or payment purpose where appropriate;
  • business history, financial or processing history relevant to the transaction;
  • expected transaction volume, delivery period and Buyer concentration;
  • supporting Service Orders, invoices, contracts or delivery evidence; and
  • information needed to resolve sanctions, adverse-risk or jurisdictional questions.

Playto may approve, decline, limit or place conditions on an account or transaction after review. Review requirements should be proportionate to the identified risk and do not create a promise of approval.

Playto may consider information published by the Financial Action Task Force (FATF), sanctions authorities, payment networks, financial institutions and other credible regulatory or risk sources when assessing geographic risk.

FATF's jurisdictions under increased monitoring are commonly referred to as the "grey list." Inclusion means that the jurisdiction is working with FATF to address identified strategic deficiencies. FATF does not, merely because a jurisdiction is grey-listed, call for blanket enhanced due diligence or the wholesale exclusion of customers from that jurisdiction. Playto therefore uses a risk-based approach while separately applying its own operating restrictions and any mandatory legal requirements.

FATF separately identifies high-risk jurisdictions subject to a call for action. Playto may apply stricter treatment to those jurisdictions and may also block additional jurisdictions for legal, contractual, payment, banking or risk reasons.

Playto's lists may therefore be broader, narrower or organized differently from an external list. If Playto's policy is stricter than an external monitoring classification, the Playto restriction governs use of Playto.

Geographic eligibility does not replace sanctions or restricted-party screening. A person or entity may be prohibited or restricted even if located in a jurisdiction that Playto otherwise supports.

Playto may screen relevant parties, owners, controllers, counterparties, payment participants and transaction information against sanctions or restricted-party lists administered by the United States and, where applicable to the transaction or Playto's obligations, other relevant authorities.

Where applicable law prohibits a transaction, Playto will not proceed merely because the country itself is not on Playto's Blocked list. You must not use Playto to transact directly or indirectly with a blocked or prohibited person, make funds or services available to such a person where prohibited, or evade an applicable sanctions, export-control or trade restriction.

A business may be restricted because of its ownership even when the business name does not appear on a sanctions list. Playto may therefore request and assess direct and indirect ownership information and may require clarification of complex ownership structures.

Where an applicable sanctions regime treats an entity as blocked or restricted because sanctioned persons hold the relevant aggregate ownership interest, Playto will apply that rule. For U.S. sanctions, this includes the applicable OFAC ownership principles. Control, agency, board involvement or other participation by a sanctioned person may also require additional legal review even when an automatic ownership rule is not triggered.

Do not conceal beneficial owners, nominees, controlling persons, sanctioned interests or the involvement of a restricted person in a transaction.

Playto may consider more than the address entered at checkout. Relevant locations can include:

  • the Service Partner's place of incorporation, residence where relevant, and actual operations;
  • the Buyer's place of establishment and actual business location;
  • the location of beneficial owners or representatives where legally relevant;
  • where the Service is performed, delivered or primarily used;
  • the location and ownership of the payment or payout account;
  • the destination or beneficiary of the Service; and
  • other locations materially connected to the transaction.

No single address field determines eligibility where the surrounding facts show a different geographic connection.

Nationality or citizenship alone is not necessarily the same as current residence or business location. However, citizenship can still matter where an applicable sanctions or legal rule makes it relevant. Playto may request evidence of lawful residence or operating location when the facts require it.

You must provide accurate location information and update it when a material change occurs. Playto may request reasonable evidence such as registration records, operating addresses, tax information, payment-account ownership or other reliable documents where needed to verify location.

A virtual office, mail-forwarding address, nominee address, VPN, proxy, foreign payment account or incorporation in a supported jurisdiction does not by itself establish that the underlying business or transaction is located there.

Playto may pause a transaction while a material location discrepancy is investigated.

You must not structure a transaction to evade this Policy. Prohibited circumvention includes:

  • routing a payment through a person in a supported country for a blocked beneficiary;
  • using a shell or affiliate solely to disguise the actual Service Partner, Buyer or destination;
  • splitting a transaction to avoid geographic controls;
  • misstating the place of performance or delivery;
  • using an unrelated third-party payout account to disguise the recipient; or
  • asking Playto to describe a restricted transaction as a different permitted Service.

Playto assesses the substance of the transaction rather than only the payment route.

A Buyer must provide accurate billing, business and transaction information and must not use Playto to purchase a Service for a prohibited person, prohibited destination or restricted activity.

A supported Buyer location does not make a transaction permissible if the actual Service recipient, destination, contracting party or other material participant is blocked or prohibited.

Where Playto cannot lawfully or operationally complete the transaction, Playto may decline or cancel it and handle any affected funds under the Buyer Terms, Refund & Cancellation Policy and applicable law.

A Service Partner must not use a Playto account to serve a blocked jurisdiction, prohibited person or undisclosed third party where the transaction would violate this Policy.

The Service Partner must disclose material jurisdictional facts in the Service Order and promptly notify Playto if it learns that the Buyer, beneficiary, place of performance or destination is materially different from the information previously provided.

Approval of the Service Partner's business does not approve every Buyer country or transaction. A new geography may require review even where the underlying Service is already approved.

Playto may decline, pause, cancel or restrict a payment or payout where a jurisdiction, sanctions or geographic-risk issue requires review or prevents lawful or supported completion.

If a payment has already been authorized or collected, Playto will handle the affected amount according to the Buyer Terms, Service Partner Terms, the applicable payment rules and applicable law. A geographic restriction does not create a right to reroute funds to an unrelated person, alternate country or substitute bank account.

A Service Partner may not replace the actual recipient or payout destination merely to avoid a restriction. Settlement, reserves, set-off and recovery remain governed by the Supplier Settlement, Reserves & Set-Off Policy and Service Partner Terms.

Different legal restrictions can require different treatment. Depending on the applicable rule, a transaction or amount may need to be blocked or frozen, rejected, returned through a permitted route, reported, or otherwise restricted.

Where applicable law requires Playto or another regulated participant to block or freeze property, Playto may be unable to return or release the affected amount until legally permitted. Where a transaction must instead be rejected or returned, Playto will use the lawful process available for that transaction.

A legal blocking or rejection requirement is different from Playto voluntarily placing a commercial reserve. Playto will record the restriction accordingly and provide information to the extent permitted by law.

Nothing in this Policy requires Playto to complete, refund, transfer or redirect a transaction in a way that would itself violate applicable law.

Jurisdiction risk can change. Sanctions, FATF monitoring, payment availability, banking support, regulatory requirements and Playto's risk appetite may change after an account is approved.

Playto may update this Policy prospectively. Where law, sanctions or a binding payment restriction requires immediate action, Playto may act without advance notice. For a discretionary Playto policy change that materially affects an existing approved relationship, Playto will provide reasonable notice where practicable.

Removal from an external sanctions or monitoring list does not automatically require Playto to enable a jurisdiction. Similarly, Playto may restrict a jurisdiction before an external list changes where its own legal, payment, banking or risk assessment requires it.

If a jurisdiction becomes restricted while a Service Order is already in progress, Playto will determine the lawful treatment of the affected transaction based on the applicable restriction, stage of performance and available permissions.

Possible outcomes may include lawful completion, suspension, cancellation, refund, restricted settlement, evidence preservation or another required wind-down step. No party should continue prohibited performance merely to finish an existing project.

Existing Buyer rights, Service Partner obligations and required records survive to the extent they can lawfully be performed.

Knowingly providing false or incomplete geographic information is a material policy violation and may result in transaction rejection, account restriction or termination under the governing terms.

An ordinary mistake should be corrected promptly. Playto may distinguish good-faith error from deliberate evasion based on the surrounding evidence and transaction history.

Correcting an address does not require Playto to approve a transaction that remains prohibited or outside the supported model.

If you believe a jurisdiction decision is based on incorrect or outdated factual information, contact support@playto.so with the account or transaction reference and the information you believe should be corrected.

Playto may request supporting evidence and will review information it is permitted to consider. A review can correct factual errors, but it does not guarantee approval, override a legal prohibition, require Playto to make an exception to a Blocked-jurisdiction policy, or require disclosure of confidential screening methods.

If Playto identifies that a jurisdiction has been placed in the wrong internal category because of a policy-maintenance error, Playto may correct the published classification. A request for review is not itself authorization to transact while the restriction remains in effect.

A jurisdiction not appearing on the Blocked or Enhanced Review lists is not guaranteed to be available for every Service Partner, Buyer, currency, payment method, payout route or transaction.

Availability can depend on the approved Service, transaction amount, delivery period, Buyer and supplier profile, business history, current payment capabilities, tax or regulatory requirements, sanctions screening and other risk factors.

Do not represent Playto as supporting a country, payment route or payout destination until that availability is actually shown or confirmed for the relevant account and transaction. Marketing references to a broad number of supported markets must remain consistent with the current operational availability reflected by Playto's systems and policies.

This Policy addresses geography and jurisdiction risk. It does not replace the separate rules governing acceptable services, Buyer payments, refunds, recurring billing, delivery, supplier settlement, taxes, privacy or other legal obligations.

Where more than one restriction applies, the stricter applicable restriction governs the affected use of Playto. A jurisdiction approval does not waive an acceptable-use restriction, and an eligible Service does not override a sanctions or restricted-party prohibition.

Nothing in this Policy represents that Playto has completed licensing, tax registration, payment-method availability, banking support or legal clearance for every unlisted jurisdiction. Geographic availability should be implemented only where the actual product and operating arrangements support it.

Questions about jurisdiction eligibility, a transaction restriction or a review request may be sent to support@playto.so.

Please include the relevant business name, transaction or account reference, jurisdiction and a concise explanation. Do not send passwords, full payment credentials or unnecessary sensitive documents by ordinary email.

Playto, Inc.
8 The Green, Ste R
Dover, DE 19901
United States