Introduction
UAB UniPayment's Customer Acceptance Policy defines the use and limitations on its services. It covers both Personal and Corporate customers across various business sectors, countries, and transaction types, evaluating them on a case-by-case basis. The policy is adaptive, allowing for restrictions or prohibitions under certain circumstances.
Definitions
Prohibited: Activities or entities not accepted under any scenario.
Restricted: Activities or entities subject to approval, evaluated individually.
Permitted: Generally acceptable activities or entities, barring specific exceptions.
Jurisdictions
Prohibited Jurisdictions
Our services cannot be extended to individuals or entities based in countries identified on our prohibited list. This restriction also applies to beneficial owners or directors from these locations, with potential exceptions subject to approval by our Banking Partner's MLRO. The list further encompasses any nation enforcing 'Capital Control' laws.
Country | Code |
Afghanistan | AF |
American Samoa | AS |
Angola | AO |
Bangladesh | BD |
Barbados | BB |
Benin | BJ |
Guinea-Bissau | GW |
Bolivia | BO |
Botswana | BW |
Brunei | BN |
Burkina Faso | BF |
Burundi | BI |
Central African Republic | CF |
China | CN |
Dominica | DM |
Ivory Coast (Côte d'Ivoire) | CI |
Djibouti | DJ |
Eritrea | ER |
Ethiopia | ET |
Fiji | FJ |
Gabon | GA |
Guyana | GY |
Gambia | GM |
Ghana | GH |
Guam | GU |
Guinea | GN |
Haiti | HT |
Honduras | HN |
Iraq | IQ |
Iran | IR |
U.S. Virgin Islands | VI |
Jamaica | JM |
Yemen | YE |
United States Minor Outlying Islands | UM |
Cayman Islands | KY |
Christmas Island | CX |
Cambodia | KH |
Cameroon | CM |
Kyrgyzstan | KG |
Kiribati | KI |
Congo | CG |
Democratic Republic of the Congo | CD |
Kosovo | XK |
Crimea | UA |
Cuba | CU |
Laos | LA |
Lesotho | LS |
Lebanon | LB |
Liberia | LR |
Libya | LY |
Madagascar | MG |
Malawi | MW |
Maldives | MV |
Mali | ML |
Mauritius | MU |
Mauritania | MR |
Myanmar | MM |
Micronesia | FM |
Mongolia | MN |
Mozambique | MZ |
Namibia | NA |
Nauru | NR |
Nigeria | NG |
Niger | NE |
Nicaragua | NI |
Niue | NU |
Pakistan | PK |
Palau | PW |
Palestinian Territories | PS |
Panama | PA |
Papua New Guinea | PG |
South Sudan | SS |
Pitcairn Islands | PN |
French Southern Territories | TF |
Equatorial Guinea | GQ |
Rwanda | RW |
Russia | RU |
East Timor (Timor-Leste) | TL |
Samoa | WS |
São Tomé and Príncipe | ST |
Senegal | SN |
Sierra Leone | SL |
Syria | SY |
Somalia | SO |
Sudan | SD |
Eswatini (Swaziland) | SZ |
Tajikistan | TJ |
Tanzania | TZ |
Turks and Caicos Islands | TC |
Togo | TG |
Tokelau | TK |
Tonga | TO |
Trinidad and Tobago | TT |
Turkmenistan | TM |
Tuvalu | TV |
Uganda | UG |
Western Sahara | EH |
Vanuatu | VU |
Vatican City (Holy See) | VA |
Venezuela | VE |
Zambia | ZM |
Zimbabwe | ZW |
Chad | TD |
North Korea (Democratic People's Republic of Korea) | KP |
Sri Lanka | LK |
Prohibited Activities
Commercial logging operations or purchase of logging equipment for use in the primary tropical moist forest;
Creation of indecent and obscene material including child pornography;
Diamond trading without Kimberley Certification;
Drift net fishing in the marine environment using nets in excess of 2.5km in length;
Drug trafficking including chemicals used to manufacture a synthetic drug or drugs;
Giving or receiving gifts that could be interpreted as intending to influence business decisions;
Illegal use of confidential material and non-public information;
Involvement in any business relating to prostitution;
Money exchange dealings;
Non-licensed forex/binary options;
Non-licensed offline gambling/betting/casino/horse racing/bingo/sports betting;
Non-licensed online casino/online poker/online gambling/online betting/prize draws/gift cards/any form of lottery/scratch cards;
Production or activities involving harmful or exploitative forms of forced labor /harmful child labor;
Production or trade in any product or activity deemed illegal under host country laws or regulations or international conventions and agreements, including without limitation host country requirements related to environmental, health and safety, and labor aspects;
Production or trade in ozone-depleting substances subject to international phase-out;
Production or trade in pesticides/herbicides subject to international phase-outs or bans;
Production or trade in pharmaceuticals subject to international phase-outs or bans;
Production or trade in radioactive materials;
Production or trade in weapons and munitions;
Production or trade in wood or other forestry products from unmanaged forests;
Production, trade, storage, or transport of significant volumes of hazardous chemicals, or commercial scale usage of hazardous chemicals;
Quarries, mining, or processing of metal ores or coal;
Trade in wildlife or wildlife products regulated under CITES;
Trading of animal fur, bones, and ivory;
Trading of bearer shares and bonds;
Trading of cultural objects like sculptures, statues, antiques, collectors’ items, and archaeological pieces especially those originating from the Republic of Iraq;
Trading of fireworks, explosives, and weapons;
Trading in derivatives/options/hedging;
The dealing of jewels, gems, and precious metals.
Restricted Jurisdictions
Individuals or entities from jurisdictions not explicitly mentioned may still be eligible for our services, evaluated individually. The Compliance team will assess such onboarding applications, especially focusing on those with payment needs in major markets including the US, Canada, and UK
Certain customer types are identified as carrying a higher level of risk, necessitating further due diligence. Should there be limitations on publicly available information or if the risk is considered too high, such customers will not be permitted to engage in transactions with us.
For details for Jurisdictions, please refer to Appendix-Jurisdictions
Type of Legal Entity
Permitted Legal Entities
Limited Liability Companies (‘LTD’)
Public Listed Companies (‘PLC’)
Prohibited Legal Entities
Customers cannot be accepted where the legal form of the contracting entity is:
Unregistered charity or foundation
A company with bearer shares
Shell Companies
LLP Form
Us Entities with no Substance
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
Companies pending incorporation or legal registration – proof of application with the relevant authorities must be provided
Business Sector
UAB UniPayment does not offer services to entities engaged in the following types of activities or services:
Business Sector | Activity/Service |
Adult/Dating | Escort/Prostitution Agencies Pornography featuring children, rape, humiliation, or bestiality C2B Adult Content Any other form of pornography depicting sexual intercourse C2B |
CBD | Marijuana dispensaries |
CFD Trading/Spread betting | Unregulated CFD/FX traders Unlicensed Binary Options CFD Brokers licensed within the following jurisdictions: Marshall Islands or other jurisdiction without public register of UBO and directors |
Cryptocurrency
Blockchain
| ATMs Unregulated cryptocurrency exchanges (or any other related services) where licensing or registration for AML/CFT purposes is a legal requirement Cryptocurrency businesses with insufficient KYC & CDD practices |
Financial Services | Unregulated or inadequately licensed financial institutions/money service businesses Lending, including Pay-day lenders outside USA Unregulated account aggregation |
Gambling | Any type of C2B Cassino/Gambling Unlicensed gambling activities Unlicensed Binary Options Skins/loot box trading |
Get-rich-quick Schemes | Any schemes marketed as get-rich-quick Pyramid Schemes
|
Pharmaceuticals | Any type of distribution of Medical products Drug related paraphernalia, e.g., selling bongs, hookah Illegal/synthetic drugs or prescription drugs without a prescription
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Speciality Retail | Counterfeit goods Human bodyparts Offensive goods related to crime, e.g. photographs memorabilia Weapons (including firearms) Tobacco & Electronic cigarettes Pyrotechnic devices and hazardous materials, e.g. fireworks, explosives, toxic/flammable goods Animals and Livestock Stolen Property Police-related items Mailing lists and personal information Government documents and IDs Lock picking devices
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