Eligibility

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:

• Arms Trade and defense;
• Adult entertainment and pornography;
• Physically present Adult Services;
• Synthetic stimulants;
• Unofficial charities;
• Businesses violating intellectual property rights;
• Illegal Drugs; Illegal Sale of Prescription Drugs; Illegal sale or distribution of recreational drugs;
• Cryptocurrency mining;
• Businesses involved in Cryptocurrency or Crypto assets trading;
• Illegal, unregulated, unlicensed, or unauthorised gambling or gaming firms (remote and non-remote)
• Forex robots;
• Political or Religious organizations;
• Replicas;
• Unregulated or unlicensed money service businesses, including currency exchange and lending;
• Trafficking of cultural artefacts and/or wildlife or protected species;
• Human Trafficking, modern slavery, and any other illegal activity;
• Shell formations or pose any sign of a shell formations;
• MLM (attracting new members basis);
• Offenders of environmental regulations and perpetrators of environmental crime;
• Online gambling and auxiliary payment processors (where the gambling license is outside the UK or EU);
• Entities or individuals under Sanctions.

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. Restricted businesses (we will require enhanced due diligence):

• Gambling/gaming/betting activities;
• Forex brokers/ forex consulting/advisers;
• Intermediary services in real estate trading;
• Travel/ booking/ticket agencies;
• Cash intensive services such as nail bars/salons, scrap metal dealers, and cash processing/courier services;
• Crypto related businesses;
• Crowdfunding platforms;
• Charities, non-profit organisations, foundations, and cultural associations;
  money or value transfer service businesses (including check cashing and prepaid cards) or alternative banking platforms;
• Extractive services, such as mining or crude oil/gas;
• Lawful recreational drugs/medicinal marijuana distributors;
• The professional football sector;
• General trading companies operating in a Free Trade Zone (FTZ);
• High Value Dealers, such as jewelry and precious metals dealers including those that purchase metals from pawnbrokers and other secondary sources, arts and antiques markets, auctioneers, builders, and motor vehicle and boats dealers, including parts;
• Other high-risk activities including embassies/consulates, independent legal professionals such as Trust
• Company Service Providers (TCSPs), travel and tour companies, payroll services and the tobacco industry.

4. The Company determined the following economic or other activities deemed to be of Elevated risk:

• Consultancy services;
• Digital marketing;
• Web development;
• Trainings, online courses;
• Financial services, loans/money lending businesses;
• Production and distribution of alcoholic beverages;
• Telecommunication services/computer network or information services/data storage, sharing services;
• Import/export and cross-border logistics companies;
• IT services that are not related to IT hardware manufacturing and trading.

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:

High risk transaction fee may be applied to payments to/from the following countries: .

We consider these countries as high risk: .

List of countries with which we do not process any transactions: .