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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:

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):

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

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:



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: .

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