CLIENT ONBOARDING RESTRICTIONS

1. Prohibited industries

The Company does not deal with persons, who are directly or indirectly involved in illegal or unregulated businesses, including, but not limited to:

1. Unofficial charity

2. Businesses involved in Cryptocurrency or Crypto assets trading (For any purpose)

3. Political organizations

4. Pornography

5. Prescription drugs

6. Religious organizations

7. Replicas

8. Arms trade and defense

9. MLM (attracting new members basis)

10.  Forex robots

11.  Non-EU forex, gambling or betting

12.  Streaming or sales of video/audio or other type of content

13.  Businesses violating intellectual property rights

14.  Online gambling and auxiliary payment processors (where the gambling license is outside the UK or EU)

2. Prohibited business types

1. Intermediary companies acting between, for example, manufacturers and the end users (a.k.a. trading companies that only serves as a middle man). Usually registered in offshore territories but these can also be, for example, European Union companies which serve the same purpose.

2. Shell companies that can be identified based on the below criteria (definition) – a legal person characterized by one or several of the following indications:

2.1. no affiliation of a legal person to an actual economic activity or the operation of a legal person generates a minor economic value or no economic value at all, and there is no documentary information that would prove the contrary.

2.2. laws and regulations of the country where the legal person is registered do not provide for an obligation to prepare and submit financial statements for its activities to the supervisory authorities of the relevant country, including annual financial statements.

2.3. the legal person has no place (premises) for the performance of economic activity in the country where the relevant legal person is registered;

3. Business subject to sanctions risks

Companies the business of which involves the export of the following commodity types to Russia and Belarus:

3.1. Horses;

3.2. Caviar and caviar substitutes;

3.3. Truffles and preparations thereof;

3.4. Wines;

3.5. Cigars or cigarillos;

3.6. Perfumes, toilet waters and cosmetics;

3.7. Leather, saddlery, travel goods, handbags or similar articles;

3.8. Garments, clothing, accessories or shoes;

3.9. Carpets, rugs and tapestries;

3.10. Pearls, precious and semi-precious stones, articles of pearls, jewelry, gold;

3.11. Coins and banknotes (not legal tender items);

3.12. Any item of cutlery, bladed or edged instruments;

3.13. Tableware of porcelain, china, stoneware or earthenware or fine pottery;

3.14. Items of lead crystal (products containing at least 24% of lead oxide) including specific non-electric lamps but on condition that they are made of lead crystal;

3.15. Electronic items for domestic use (this is about home appliances);

3.16. Electrical/electronic or optical apparatus for recording and reproducing sound and images;

3.17. Vehicles, except ambulances;

3.18. Clocks and watches and their parts;

3.19. Musical instruments;

3.20. Works of art, collectors’ pieces and antiques;

3.21. Articles and equipment for sports;

3.22. Articles and equipment for billiards, automatic bowling, casino games.

Additionally:

3.23. Iron and steel products;

3.24. Oil refining goods and technology;

3.25. Quantum computing and advanced materials goods and technology.

General rule 1:

No export to Russia and Belarus of any commodity the customs code of which falls into the category of military or dual-use goods or commodity listed in the respective sanctions lists:

§ https://www.legislation.gov.uk/uksi/2022/452/schedule/part/2/made

§ https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022R0428

§ https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02014R0833-20220316

General rule 2:

Import of goods from Russia is subject to individual evaluation (Crimea and Sevastopol links are under a complete ban) but the commodity listed in the respective sanctions lists (see above) is not acceptable.