Last Updated September 25, 2024
Version 1.0
Conduit, Asset Partner A, Asset Partner B Restricted Industries List
Classification | Examples (NOT EXHAUSTIVE!) |
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Abusing or misusing Conduit or as expressly prohibited by the Conduit agreements | Self-dealing; used for personal, family or household purposes; used if the client knows it does not have the financial resources to send Conduit funds and that includes the obligation to understand whether the client's jurisdiction imposes any controls on the cross-border flow of capital which may affect the client's ability to send Conduit funds as indicated; provided to, or used for the benefit of, a person, customer, entity, organization, or country that is blocked or sanctioned by the U.S., Canada, the EU, UK, United Nations, or any other relevant jurisdiction, including those identified on OFAC’s various sanctions lists and the UNSC Consolidated List and the European Union’s Consolidated List of Sanctions and Canadian Sanctions; used by or for the benefit of unaffiliated third-parties; used for any other activities not for the client's or the client's customer's commercial benefit; or used for any purpose that is unlawful or prohibited by Conduit contracts and agreements, or any of Conduit's financial partners |
Aggregation businesses | Engaging in any form of licensed or unlicensed aggregation of funds owed to third parties, or other activities intended to obfuscate the origin of funds; payment facilitation |
Bearer share companies | Shares of companies that are issued as bearer shares and not immobilized by a regulated and/or authorized custodian that maintains full enhanced due diligence records for each owner of such bearer shares |
Counterfeit or unauthorized goods | Counterfeit goods; unauthorized sale or resale of brand name or designer products or services; sale of goods or services that are illegally imported or exported |
Foreign Exchange Trading | Businesses that accept one currency for another, unless directly regulated and licensed by local financial regulatory authorities (e.g., a client that is a licensed and regulated bank in their country of domicile) |
Get rich quick schemes, multi-level marketing, pyramid schemes | Investment opportunities or other services that promise high rewards, including multi-level marketing and pyramid schemes |
Intellectual property or proprietary rights infringement | Sales, distribution, or access to counterfeit music, movies, software, or other licensed materials without the appropriate authorization from the rights holder; any product or service that directly infringes or facilitates infringement upon the trademark, patent, copyright, trade secrets, or proprietary or privacy rights of any third party; use of Conduit's intellectual property without prior written consent from Conduit or in a manner that otherwise harms Conduit or the Conduit brand; any action that implies an untrue endorsement by or affiliation with Conduit |
Internet gambling | Internet gambling sites |
Marijuana-related businesses; illegal products or services; weapons and munitions; explosives; toxic materials; pseudo-medical | Depending on the country, this may include marijuana-related businesses (MRBs); cannabidiol-related businesses (CBDs); equipment for making or using drugs, such as bongs and vaporizers; drug trafficking; illicit drug distribution; fake references, fake IDs, fake invoices, and other fake-providing services; weapons and munitions; gunpowder and other explosives; weapons of mass destruction; fireworks and related goods; toxic, flammable, and radioactive materials; goods or services, the sale of which is illegal under applicable law in the jurisdictions to which your business is targeted or directed; pseudo-medical and pseudo-pharmaceutical businesses |
No-value-added services | Sale or resale of a service without added benefit to the buyer; resale of government offerings without authorization or added value; sites that we determine in our sole discretion to be unfair, deceptive, or predatory towards consumers |
Pornography, obscene materials, and other adult content goods and services | Pornography and other obscene materials (including literature, imagery, and other media) depicting nudity or explicitly sexual acts; sites offering any sexually related services such as prostitution, escorts, pay-per view, adult live chat features; sexually oriented items (e.g., adult toys); adult video stores; sexually oriented massage parlors; gentleman's clubs, topless bars, and strip clubs; sexually oriented dating services |
Precious metals and gems | Dealers and other businesses focused on the precious metals and gems industries |
Prepaid products and other high-risk businesses | Prepaid cards, prepaid phone cards; telecommunications manipulation equipment; forwarding brokers; negative response marketing; charities without proper registration; any businesses that we believe poses elevated financial risk, legal liability, or violates financial partner policies; any business or organization that — engages in, encourages, promotes or celebrates unlawful violence or physical harm to persons or property, or engages in, encourages, promotes or celebrates unlawful violence toward any group based on race, religion, disability, gender, sexual orientation, national origin, or any other immutable characteristic; unlicensed or unregistered money services businesses and money transmitters; shell banks; payday lenders, lenders that charge very high interest rates for short-term loans, and lenders that take advantage of the economically disadvantaged |
Unethical mugshot publication or pay-to-remove sites | Platforms that facilitate the publication and removal of content (such as mug shots), where the primary purpose of posting such content is to cause or raise concerns of reputational harm |
Unethical social media promotional activities | Sales of Twitter followers, Facebook likes, YouTube views, and other forms of unethical social media activity / online traffic |
Video game or virtual world credits | Fiat sales of in-game currency or game items without a robust KYC identity verification program |
Asset Partner A (Additional Restricted Industries)
Digital Assets | Direct onboarding or offboarding of digital assets and digital asset peer-to-peer payments |
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Governmental | Missions, embassies, and consulates |