• 1. Introduction
  • 2. Definitions
  • 3. Jurisdictions
  • 4. Type of Legal Entity
  • 5. Business Sectors
  • 6. Transactions

CLIENT TYPE & JURISDICTION ACCEPTANCE POLICY

Last modified: May 15, 2024

1. INTRODUCTION

This Customer Acceptance Policy (“Policy”) outlines the acceptable use of and restrictions on [Company Name] Group’s (“UPAY ” Herein) products and services. The lists in this Policy are not exhaustive and where a customer, business sector, country or transaction type is not covered within this policy it may be generally acceptable, but will be considered on a case-by-case basis. From time to time it may be necessary for us to prohibit a customer depending on the particular circumstances. This policy is applicable to [Company Name], registration number [Company Number]. [Company Name]’s registered address is [Registered Address].

2. DEFINITIONS

For the purpose of this Policy, the following definitions apply:

High Risk or Banned: Not permitted or accepted by [Company Name] under any circumstances.

Medium Risk: Permitted or accepted only on a case-by-case basis, at UPAY ’s sole discretion.

Low Risk: Generally accepted by UPAY, except where OTHER specific regulatory circumstances arise.

3. JURISDICTIONS

3.1 Low Risk – Permitted Jurisdictions:

  • North America: Canada

  • EEA region and Switzerland: Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden.

  • United Kingdom, subjected to the non-solicitation act.

  • Australia, subjected to the non-solicitation.

3.2 High-Risk / Banned Jurisdictions:

[Company Name] is not able to offer services to customers located in any of the below listed prohibited countries. The prohibition also extends to beneficial owners and/or directors located in any of these countries, unless an exception is granted by the [Company Name] MLRO:

Afghanistan

Mozambique

Albania

Myanmar

Armenia

Nicaragua

Azerbaijan

North Korea

Barbados

Pakistan

Belarus

Palestine

Botswana

Panama

Burkina Faso

Philippines

Burundi

Russia

Cambodia

Senegal

Central African Republic

Somalia

Cuba

South Sudan

Democratic People’s Republic of Congo

Sudan

Ghana

Syria

Guinea

Tajikistan

Guinea-Bissau

Tanzania

Haiti

Trinidad & Tobago

Iran

Tunisia

Iraq

Turkey

Jamaica

Turkmenistan

Japan

Uganda

Jordan

Ukraine

Kazakhstan

United States

Kyrgyzstan

Uzbekistan

Libya

Vanuatu

Mali

Venezuela

Moldova

Yemen

Morocco

Zimbabwe

Customers located in other jurisdictions not specifically covered in sections 3.1 or 3.2 above may be considered on a case-by-case basis

4. TYPE OF LEGAL ENTITY

4.1. Permitted Legal Entities

  • Limited Liability Companies (‘LTD’)

  • Public Listed Companies (‘PLC’)

4.2. Prohibited Legal Entities

Customers cannot be accepted where the legal form of the contracting entity is:

  • Holding company for a private individual

  • Unregistered charity or foundation

  • A company with bearer shares

  • Dormant Company

  • Shell Companies

4.3. Restricted Legal Entities

Customers are restricted where the legal form of the contracting entity is:

  • Private/Limited Partnerships

  • Registered Charity or Foundation – additional due diligence is required

  • Sole proprietor/trader – additional due diligence will be required

  • A trust – additional due diligence is required to ensure that the trust’s beneficial owners are appropriately identified and verified, and that the trust is not being used as a vehicle to illegally evade the payment of tax

  • Private equity funds/special purpose vehicles/sovereign wealth funds or any other legal entity other than a conventional limited liability company or public limited company – any specialist structures other than a normal trading company/PLC fall outside the Compliance Department’s normal onboarding policies and will need to be scoped before any commercials are agreed. Additional time for onboarding is likely to be required

  • Micro Enterprises

  • Companies pending incorporation or legal registration – proof of application with the relevant authorities must be provided.

5. BUSINESS SECTORS RISK LEVELS AND ACCEPTANCE POLICY

5.1    Banned and 5.2 High Risk Business Sectors:

BANNED: THE FOLLOWING BUSINESS SECTORS WILL BE REJECTED FOR ONBOARDING WITHOUT CONSIDERATION

HIGH RISK: IN MOST CASES THE FOLLOWING BUSINESS SECTORS WILL BE REJECTED FOR ONBOARDIN

[Company Name] defines businesses as BANNED or HIGH RISK according to the table below:

BANNED Drugs, Drug Proprietors, and Druggist’s Sundries  
BANNED Petroleum and Petroleum Products Wholesale Distributors and Manufacturers
BANNED Drug Stores and Pharmacies Miscellaneous Stores.
BANNED Package Stores – Beer, Wine, and Liquor Miscellaneous Stores.
BANNED Direct Marketing – Insurance Service  
BANNED Mail Order Houses Including Catalog Order Stores, Book/Record Clubs (No longer permitted for U.S. original presentments)  
BANNED Direct Marketing – Catalog Merchant  
BANNED Direct Marketing – Catalog and Catalog and Retail Merchant  
BANNED Direct Marketing- Outbound Telemarketing Merchant  
BANNED Direct Marketing – Inbound Teleservices Merchant  
BANNED Direct Marketing – Continuity/Subscription Merchant  
BANNED Direct Marketing – Not Elsewhere Classified  
BANNED Fuel – Fuel Oil, Wood, Coal, Liquefied Petroleum  
BANNED Any controlled substance including but not limited to tobacco, alcohol, cannabis, drugs or medication, pharma products of any kind and their associated paraphernalia or its location/place of business. Marijuana dispensaries, transportation, distribution, possession or any activity relating to it including payments or financial dealing of any kind. 
BANNED Insurance Sales, Underwriting, and Premiums  
BANNED Insurance Premiums, (no longer valid for first presentment work)  
BANNED Insurance Not Elsewhere Classified (no longer valid for first presentment work)  
BANNED Protective and Security Services – Including Armored Cars and Guard Dogs  
BANNED Charitable and Social Service Organizations Charitable (non-political) organizations that solicit contributions, social service organizations that provide social welfare services, advocacy groups, community organizations, and health agencies. (TCC of T for fundraising performed through non–face-to-face methods such as phone orders.)
BANNED Civic, Fraternal, and Social Associations Associations engaged in civic, social, or fraternal activities. Such associations include alumni associations and clubs, booster clubs, businesspersons clubs, community membership clubs, fraternal lodges, fraternities and sororities, social clubs, veterans’ organizations, and youth associations. The activities of these groups may include political fund-raising.
BANNED Political Organizations Membership organizations that promote the interests of a national, state, or local political party or candidate, including political groups organized specifically to raise funds for a political party or individual candidate.
BANNED Religious Organizations Religious organizations that provide worship services, religious training or study, religious activities, and fund-raising. Examples are churches, convents, monasteries, mosques, shrines, synagogues, and temples.
HIGH Airlines  
HIGH Car Rental  
HIGH Hotels/Motels/Inns/Resorts  
HIGH Local/Suburban Commuter Passenger Transportation – Railroads, Ferries, Local Water Transportation.  
HIGH Ambulance Services  
HIGH Taxicabs and Limousines  
HIGH Bus Lines, Including Charters, Tour Buses  
HIGH Motor Freight Carriers, Moving and Storage Companies, Trucking – Local/Long Distance, Delivery Services – Local  
HIGH Courier Services – Air or Ground, Freight forwarders  
HIGH Public warehousing, Storage  
HIGH Cruise and Steamship Lines  
HIGH Boat Rentals and Leases  
HIGH Marinas, Marine Service, and Supplies  
HIGH Airlines, Air Carriers Not Listed Elsewhere  
HIGH Airports, Airport Terminals, Flying Fields  
HIGH Travel Agencies and Tour Operations  
HIGH Package Tour Operators (for use in Germany only)  
HIGH Toll and Bridge Fees  
HIGH Transportation Services Not Elsewhere Classified  
HIGH Telecommunications Equipment including telephone sales  
HIGH Fax services, Telecommunication Services  
HIGH Computer Network Services  
HIGH Telegraph services  
HIGH Money Orders – Wire Transfer  
HIGH Cable and other pay television (previously Cable Services)  
HIGH Electric, Gas, Sanitary and Water Utilities  
HIGH Motor vehicle supplies and new parts  
HIGH Computers, Computer Peripheral Equipment, Software  
HIGH Precious Stones and Metals, Watches and Jewelry

 Diamonds

All Precious Metals – e.g. gold and silver

(Must be regulated under local AML regulation. Merchants must provide an AML policy and must be capable of producing CDD/EDD information relating to their customers on request.

Direct customer Pay-Ins approved only on a case-by-case basis. All Belgian diamond dealers are subject to the following:

·       All traders with diamond trading activities (traders dealing in loose diamonds, as well as diamond brokers and polishers) are obliged to register with the Licensing Service of the Federal Public Service Economy

 
HIGH Duty-Free Store Retail stores.
HIGH Discount Stores Retail stores.
HIGH Department Stores Retail stores.
HIGH Variety Stores Retail stores.
HIGH Miscellaneous General Merchandise Retail stores.
HIGH Grocery Stores, Supermarkets Retail stores.
HIGH Meat Provisioners – Freezer and Locker Retail stores.
HIGH Candy, Nut, and Confectionery Stores Retail stores.
HIGH Dairy Products Stores Retail stores.
HIGH Bakeries Retail stores.
HIGH Miscellaneous Food Stores – Convenience Stores and Specialty Markets Retail stores.
HIGH Car and Truck Dealers (New and Used) Sales, Service, Repairs, Parts, and Leasing  
HIGH Automobile and Truck Dealers (Used Only)  
HIGH Automobile Supply Stores  
HIGH Automotive Tire Stores  
HIGH Automotive Parts, Accessories Stores  
HIGH Service Stations (with or without ancillary services)  
HIGH Automated Fuel Dispensers  
HIGH Boat Dealers  
HIGH Recreational and Utility Trailers, Camp Dealers  
HIGH Motorcycle Dealers  
HIGH Motor Home Dealers  
HIGH

Non-Fungible Tokens (NFTs) 

 Cryptocurrency Mining

 

  
HIGH Miscellaneous Auto Dealers  
HIGH Miscellaneous Apparel and Accessory Shops Clothing Stores.
HIGH Furniture, Home Furnishings, and Equipment Stores, (Except Appliances) Miscellaneous Stores.
HIGH Computer Software Stores Miscellaneous Stores.
HIGH Caterers Service Providers.
HIGH Eating places and Restaurants Miscellaneous Stores.
HIGH Drinking Places (Alcoholic Beverages), Bars, Taverns, Cocktail lounges, Nightclubs and Discotheques Miscellaneous Stores.
HIGH Fast Food Restaurants Miscellaneous Stores.
HIGH Digital Goods: Media, Books, Movies, Music Miscellaneous Stores.
HIGH Digital Goods: Games Miscellaneous Stores.
HIGH Digital Goods: Applications (Excludes Games) Miscellaneous Stores.
HIGH Digital Goods: Large Digital Goods Merchant Miscellaneous Stores.
HIGH Used Merchandise and Secondhand Stores Miscellaneous Stores.
HIGH Antique Shops Miscellaneous Stores.
HIGH Pawn Shops and Salvage Yards Miscellaneous Stores.
HIGH Wrecking and Salvage Yards Miscellaneous Stores.
HIGH Antique Reproductions Miscellaneous Stores.
HIGH Bicycle Shops – Sales and Service Miscellaneous Stores.
HIGH Watch, Clock, Jewelry, and Silverware Stores  
HIGH Hobby, Toy, and Game Shops  
HIGH Leather Goods Stores  
HIGH Direct Marketing – Travel Related Arrangements Services  
HIGH Artist’s Supply and Craft Shops Miscellaneous Stores. (predominantly Retailers).
HIGH Art Dealers and Galleries Miscellaneous Stores. (Retailers).
HIGH Stamp and Coin Stores – Philatelic and Numismatic Supplies  
HIGH Religious Goods Stores  
HIGH Orthopedic Goods Prosthetic Devices  
HIGH Cosmetic Stores  
HIGH Pet Shops, Pet Foods, and Supplies Stores  
HIGH Miscellaneous and Specialty Retail Stores  
HIGH Financial Institutions – Merchandise and Services Such merchandise and services may include checks and other financial products, promotional merchandise, loan fees, and financial counselling service fees. (May be used in the authorization message in some CRYPTOCURRENCY transactions).
HIGH Non-Financial Institutions – Foreign Currency, Money Orders (not wire transfer) and Travelers Cheques. (Also, Non-Fiat Currency (eg, cryptocurrency), Account Funding (Not Stored Value Load), Debt Repayment). Quasi-Cash Merchant. Identifies the purchase, with a Mastercard or Maestro card, of travellers cheques, foreign currency, or money orders, or the use of a Mastercard card to open or fund a deposit account, at a location other than a Mastercard customer financial institution location. This type of industry may also be used to identify transactions in which a merchant accepts a Mastercard or Maestro card for payment of existing debt, such as a private label card or vehicle loan. In addition, this industry type must be used to identify transactions involving the purchase of CRYPTOCURRENCY.
HIGH Security Brokers/Dealers Merchants that buy, sell, and broker securities, stocks, bonds, commodities, and mutual funds. Forex.
HIGH Real Estate Agents and Managers – Rentals Fees charged by merchants engaged in the rental and management of residential and commercial properties, such as real estate agents, brokers, and managers, and apartment rental services. Such fees may include management fees, real estate rental commissions, and real estate rental payments.
HIGH Timeshares Retailers that sell, lease, and rent timeshare real estate and arrange timeshare condominium exchanges.
HIGH Dating and Escort Services Merchants that provide dating and escort services, including computer and video personal introduction and matchmaking services.
HIGH Tax Preparation Service Merchants that exclusively provide income tax return preparation services without auditing, accounting, or bookkeeping services.
HIGH Miscellaneous Personal Services Not Elsewhere Classified Personal Service Providers (merchants that do not fall under any other industries, eg animal boarding, bathhouses, house sitting services, maid services, animal grooming and kennels, real estate agent, brokers, body piercing and tattooing, and others).
HIGH Consumer Credit Reporting Agencies Business Services.
HIGH Computer Programming, Integrated Systems Design and Data Processing Services  
HIGH Computer Maintenance and Repair Services Not Elsewhere Classified  
HIGH Management, Consulting, and Public Relations Services  
HIGH

PPIs

Tax refund services

(Must come from an acquirer – no direct customer payments.)

  
HIGH Car Rental Agencies/Companies Not Elsewhere Classified or Not Listed herein  
HIGH Truck and Utility Trailer Rentals  
HIGH Motor Home and Recreational Vehicle Rentals  
HIGH Automobile Parking Lots and Garages  
HIGH Automotive Body Repair Shops  
HIGH Paint Shops – Automotive  
HIGH Automotive Service Shops  
HIGH Car Washes  
HIGH Watch, Clock, and Jewelry Repair  
HIGH (the US only) Government-Licensed On-Line Casinos (On-Line Gambling) – US Region only Is restricted to merchants located in the U.S. region and properly registered with the Card Association.
HIGH (the US only) Government-Licensed Horse/Dog Racing – US Region only Is restricted to merchants located in the U.S. region and properly registered with the Card Association.
HIGH Motion Pictures and Video Tape Production and Distribution Wholesale producers and distributors of educational and industrial films and videos for exhibition & sale, including TV commercials and training films.
HIGH Motion Picture Theaters Merchants that operate movie theatres, including drive-in theatres. Such merchants sell tickets and refreshments, and may or may not offer advance ticket reservations via the phone.
HIGH DVD / Video Tape Entertainment Rental Stores Industry: Amusement and Entertainment.
HIGH Dance Halls, Studios and Schools Industry: Amusement and Entertainment.
HIGH Theatrical Producers (except Motion Pictures), Ticket Agencies Industry: Amusement and Entertainment.
HIGH Bands, Orchestras, and Miscellaneous Entertainers Not Elsewhere Classified Industry: Amusement and Entertainment.
HIGH Billiard and Pool Establishments Industry: Amusement and Entertainment.
HIGH Contract for Differences (CFDs) Industry: Amusement and Entertainment.
HIGH Commercial Sports, Athletic Fields, Professional Sport Clubs, and Sport Promoters Industry: Amusement and Entertainment.
HIGH Non-profit associations and foundations .
HIGH Adult content, production or activities associated or facilitating adult activities including but not limited to Industry: Amusement and Entertainment.
HIGH Online gaming, gambling betting and Video Amusement Game Supplies Industry: Amusement and Entertainment.
HIGH Video Game Arcades/Establishments Industry: Amusement and Entertainment.
HIGH Betting / Gambling (including Lottery Tickets, Casino Gaming Chips, Off-track Betting and Wagers at Race Tracks) Industry: Amusement and Entertainment. Gambling.
HIGH Amusement Parks, Carnivals, Circuses, Fortune Tellers Industry: Amusement and Entertainment.
HIGH Membership Clubs (Sports, Recreation, Athletic), Country Clubs, and Private Golf Courses Industry: Amusement and Entertainment.
HIGH Aquariums, Sea-aquariums, Dolphinariums Industry: Amusement and Entertainment.
HIGH Recreation Services Not Elsewhere Classified Industry: Amusement and Entertainment.
HIGH Doctors and Physicians Not Elsewhere Classified Industry: Professional Services and Membership Organizations.
HIGH Dentists and Orthodontists Industry: Professional Services and Membership Organizations.
HIGH Claims Institutions Industry: Professional Services and Membership Organizations.
HIGH Chiropractors Industry: Professional Services and Membership Organizations.
HIGH Optometrists and Ophthalmologists Industry: Professional Services and Membership Organizations.
HIGH Opticians, Opticians Goods and Eyeglasses Industry: Professional Services and Membership Organizations.
HIGH MarketPlaces

Must be selling general marketplace goods

Must have strong controls around selling prohibited/restricted goods, including the following:

PROHIBITED:

–              Intellectual property right violation

–              Animals and wildlife

–              Stolen property

–              Police related items

–              Mailing lists and personal information

–              Government, transit, and shipping-related items

–              Government documents, IDs, and licences

–              Hazardous, restricted, or regulated materials

–              Human remains and body parts

–              Lock picking devices

–              Embargoed goods and prohibited countries

–              Encouraging illegal activity

–              Firearms, weapons, and knives

–               Drugs and drug paraphernalia RESTRICTED:

–               Adult items

–               Alcohol

–               Selling art, artifacts, cultural heritage, and grave-related items

–               Authographed items

–               Credit and debit cards

–               Digitally delivered goods

–               Gift cards

–               Coupons

–               Medical drugs, devices, and healthcare

–               Personal relationships and services

–               Real estate

–               Product safety

–               Event tickets

–               Slot machines

–               Stamps

–               Currency and coins

–               Stocks and other securities

–               Travel

–               Used cosmetics
HIGH Podiatrists and Chiropodists Industry: Professional Services and Membership Organizations.
HIGH Nursing and Personal Care Facilities Industry: Professional Services and Membership Organizations.
HIGH Hospitals, Doctors, Nurses or any other services involving medical services.  Industry: Professional Services and Membership Organizations.
HIGH Medical and Dental Laboratories Industry: Professional Services and Membership Organizations.
HIGH Medical Services and Health Practitioners Not Elsewhere Classified Industry: Professional Services and Membership Organizations.
HIGH Dealing, exchanging, hedging or holdings of precious metals or commodities included but not limited to gold, silver, oil, gas etc. or holding such commodities through a third party or as a part of an investment portfolio.  
HIGH Business and Secretarial Schools Business and secretarial schools that offer general business training such as business machine operation, office procedures, word processing, stenographic, and other clerical skills. Such schools offer a training certificate but do not offer.
HIGH Adult/Dating 

Subscription-based dating websites where users may message, chat and/or arrange interactions with other genuine users

Merchants offering webcams or any other interactive services with models (Must have clear policy and controls about age limits, human

trafficking, escorting and prostitution prevention.).
HIGH Schools and Educational Services Not Elsewhere Classified Merchants that offer educational courses and services that are not described by another more specific industry. Such merchants include schools that teach music, drama, art, cooking, modelling, karate schools, automobile driving instruction, traffic safety, flying instruction, and sewing or knitting instruction.
HIGH Child Care Services Merchants that provide child care services, including nannies, nursery schools, and daycare centres. These merchants typically care for infants and preschool children, but may also care for older children, and may or may not provide educational programs.
HIGH Collection Agencies Customers must be well established, reputable and with a history of trading
HIGH Membership Organizations Not Elsewhere Classified Industry: Professional Services and Membership Organizations. Organizations or associations that are not described by another, more specific industry. Examples include historical clubs, labour unions, poetry clubs, art councils, and tenant or condominium associations.
HIGH Testing Laboratories (non-medical) Industry: Professional Services and Membership Organizations. Merchants that provide non-medical testing services to other businesses. Examples of such services include automobile testing, calibration, and certification, food testing, forensic testing, product and pollution testing, and industrial X-ray inspection services.
HIGH Architectural – Engineering and Surveying Services Merchants that provide professional architectural, engineering, and land, water, and aerial surveying services. Included are home and building designers, ship, boat, and machine engineers and designers, and architectural engineers.
HIGH Accounting, Auditing, and Bookkeeping Services Merchants that provide accounting, bookkeeping, billing, payroll and other related auditing services, including Certified Public Accountants (CPAs). Such merchants also may provide income tax preparation services in addition to accounting and auditing services.
HIGH Professional Services Not Elsewhere Defined Merchants engaged in traditional professions that offer highly specialized services, and often require employees to obtain advanced or specialized education or training to provide the services. Examples of such merchants include mortgage brokers, research firms, financial planners, graphic designers, guest speakers and lecturers, court stenographers, real estate appraisers, research firms, and auction houses.

 

5.3 Medium Risk Activities & Business Sectors:

[Company Name] may be able to provide payment services to customers that form part of the verticals outlined below. The provision of these services will be on a case-by-case basis. As such, additional checks may need to be carried out before a decision is made and are subject to MLRO approval:

MEDIUM Advertising, Marketing and Media Buying Services Business Services.
MEDIUM Commercial Photography, Art and Graphics  
MEDIUM Quick Copy, Reproduction and Blueprinting Services  
MEDIUM Cleaning and Maintenance, Janitorial Services  
MEDIUM Employment Agencies, Temporary Help Services  
MEDIUM Equipment Rental and Leasing Services, Tool Rental, Furniture Rental, and Appliance Rental  
MEDIUM Tire Re-treading and Repair Shops Repair Services.
MEDIUM Electronics Repair Shops  
MEDIUM Furniture, Furniture Repair, and Furniture Refinishing Merchants that reupholster, repair, and refinish furniture, including restorers of antique furniture.
MEDIUM

Pharmaceuticals

Licensed merchants who sell prescription drugs online – selling of drugs online must

come from an acquirer licensed and regulated by the state regulator of a UK/EEA country.
MEDIUM Elementary and Secondary Schools Industry: Professional Services and Membership Organizations.
MEDIUM Colleges, Junior Colleges, Universities, and ProfessionalSchools Industry: Professional Services and Membership Organizations.
MEDIUM Computing/Information Technology

Data Processing

Integrated Systems Design Services

 

The following list includes the Business Sectors in general permitted under this Policy. Any vertical/business sector not covered in any part of Section 5 needs to be referred to MLRO for approval.

Business Sector

Activity Service

AISPs/PISPs

Account Information Service Providers and Payment Information Service Providers

Contract for Differences (CFDs)/FX Brokers

Brokers licensed within UK/EEA. Other allowed jurisdictions include: Australia

Switzerland New Zealand Japan

USA (subject to legal review)

Bermuda

 

  

Electronic Money Issuers

(EMI)

Regulated and adequately licensed EMIs within UK/EEA jurisdictions

Entertainment Services

Services within the entertainment sector such as restraurants, bars, and is not included in the High Risk/Banned list.

Entertainment Services

Telecom operators including fixed-network services and mobile services regulated within UK/EEA.

Financial Services

Money Service Business (including currency exchange, money remittance) Payment Institutions (including electronic communication network operators offering payment services, non-bank credit card issuers, merchant acquiring firms)

(Must be adequately licensed within UK/EEA jurisdictions)

Gambling and gaming

Licensed and regulated gambling operators within a reputable jurisdiction

(UK/EEA)
   

Introducer

Introducer to third party business for commission.

Payment Service Providers

(non-EMI)

EEA licensed PSPs which are able to hold/control client funds

Retail

Sale of merchandise that is not included in the Prohibited/Restricted list.
   

The above lists are subject to change from time to time.

 

5.4. Low Risk Activities & Business Sectors:

All industries and business sectors that are not specifically mentioned as Banned, High or Medium Risk in the previous sections of this policy.

6. TRANSACTIONS

6.1 Prohibited Transactions By Country

[Company Name] provides customers the ability to make and receive cross-border payments, however there are a number of countries that due to regulatory reasons and partner restrictions, [Company Name] is unable to facilitate payments to or from:

  • Afghanistan

  • Albania

  • Barbados

  • Belarus

  • Botswana

  • Burkina Faso

  • Burundi

  • Cambodia

  • Central African Republic

  • Cuba

  • Democratic People’s Republic of Congo

  • Ghana

  • Guinea

  • Guinea-Bissau

  • Haiti

  • Iran

  • Iraq

  • Jamaica

  • Jordan

  • Libya

  • Mali

  • Moldova

  • Morocco

  • Mozambique

  • Myanmar

  • Nicaragua

  • North Korea

  • Pakistan

  • Palestine

  • Panama

  • Philippines

  • Russia

  • Senegal

  • Somalia

  • South Sudan

  • Sudan

  • Syria

  • Tanzania

  • Trinidad & Tobago

  • Tunisia

  • Uganda

  • Ukraine

  • Vanuatu

  • Venezuela

  • Yemen

  • Zimbabwe