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Customer Acceptance Policy
Customer Acceptance Policy
Rick avatar
Written by Rick
Updated over 2 weeks ago

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

  1. Commercial logging operations or purchase of logging equipment for use in the primary tropical moist forest;

  2. Creation of indecent and obscene material including child pornography;

  3. Diamond trading without Kimberley Certification;

  4. Drift net fishing in the marine environment using nets in excess of 2.5km in length;

  5. Drug trafficking including chemicals used to manufacture a synthetic drug or drugs;

  6. Giving or receiving gifts that could be interpreted as intending to influence business decisions;

  7. Illegal use of confidential material and non-public information;

  8. Involvement in any business relating to prostitution;

  9. Money exchange dealings;

  10. Non-licensed forex/binary options;

  11. Non-licensed offline gambling/betting/casino/horse racing/bingo/sports betting;

  12. Non-licensed online casino/online poker/online gambling/online betting/prize draws/gift cards/any form of lottery/scratch cards;

  13. Production or activities involving harmful or exploitative forms of forced labor /harmful child labor;

  14. 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;

  15. Production or trade in ozone-depleting substances subject to international phase-out;

  16. Production or trade in pesticides/herbicides subject to international phase-outs or bans;

  17. Production or trade in pharmaceuticals subject to international phase-outs or bans;

  18. Production or trade in radioactive materials;

  19. Production or trade in weapons and munitions;

  20. Production or trade in wood or other forestry products from unmanaged forests;

  21. Production, trade, storage, or transport of significant volumes of hazardous chemicals, or commercial scale usage of hazardous chemicals;

  22. Quarries, mining, or processing of metal ores or coal;

  23. Trade in wildlife or wildlife products regulated under CITES;

  24. Trading of animal fur, bones, and ivory;

  25. Trading of bearer shares and bonds;

  26. Trading of cultural objects like sculptures, statues, antiques, collectors’ items, and archaeological pieces especially those originating from the Republic of Iraq;

  27. Trading of fireworks, explosives, and weapons;

  28. Trading in derivatives/options/hedging;

  29. 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

  1. Limited Liability Companies (‘LTD’)

  2. Public Listed Companies (‘PLC’)

Prohibited Legal Entities

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

  1. Unregistered charity or foundation

  2. A company with bearer shares

  3. Shell Companies

  4. LLP Form

  5. Us Entities with no Substance

Restricted Legal Entities

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

  1. Private/Limited Partnerships

  2. Registered Charity or Foundation – additional due diligence is required

  3. Sole proprietor/trader – additional due diligence will be required

  4. 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

  5. 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

  6. 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

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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