Yes it is unfortunately but so is the whole system
. As an EMI try and explain to regulators why you have 100 Iraq passport holders when they come sniffing. Try and explain to banking partners who have these countries on their blacklist why you allow them to bank with you when you send out funds and they query the transaction.
Agreed
P.S The world is an unfair place. Why you think Russians buy Malta, Cyprus or foreign passports. Passport discrimination is real in the finance industry ask an American living outside the US how FATCA has made them lepers to EMI's.