1. Introductions
This Customer Acceptance Policy ("Policy"} outlines the acceptable use of and restrictions on Unblock LT UAB ("Unblock LT"} 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.
2. Definitions
For the purpose of this Policy, the following definitions apply:
Prohibited: not permitted or accepted by Unblock LT under any circumstances.
Restricted: permitted or accepted only on a case-by-case basis, subject to prior approval by Unblock LT.
Permitted: generally accepted by Unblock LT, except where specific circumstances of a caseprevent us from doing so.
3. Jurisdictions
3.1 Prohibited Jurisdictions
Unblock LT is not able to offer services to customers located in any of the following prohibitedcountries. Reference to this list should also be extended to any Country of Residence of respective Directors/UBOs of prospective customers.
- Afghanistan
- Albania
- Belarus
- BurundiBurkina
- Faso
- Cambodia
- Central African Republic
- Cuba
- Democratic People's Republic of Congo
- Guinea
- Guinea-Bissau
- HaitiIran
- Iraq
- Libya
- Mali
- Moldova
- Myanmar
- Nicaragua
- North Korea
- Pakistan
- Russia
- Panama
- Senegal
- Somalia
- South Sudan
- Sudan
- Syria
- Tunisia
- Yemen
- Zimbabwe
4. Type of Legal Entity
There are specific forms of customers that are deemed a higher risk. As a result, some customers may be subject to additional due diligence checks. If there is a limit to the amount of information that is publicly available, or where the risk is deemed to be unacceptable, these customers will be prohibited from conducting business with Unblock LT.
4.1 Permitted Legal Entities
- Limited Liability companies
- Public Listed companies
4.2 Prohibited Legal Entities
Customers cannot be accepted where the legal form of the contracting entity is:
- A 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
5.1 Prohibited Business Sectors
Unblock LT does not provide any type of services to the following types of businesses:
Bail Bondsman
Bailiff services
CBD
Marijuana dispensaries
CFD Trading/Spread betting
- Unregulated CFD/FX traders Unlicensed Binary Options
- CFD Brokers licensed within the following jurisdictions:
- Marshall Islands
Cayman Islands VanuatuUnited Arab Emirates (UAE} - where regulatory regime is part of Sharia LawBelize
Streaming
Illicit streaming of copyright media and software
Cryptocurrency/Blockchain
- ICOs/lEOs/lDOs 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
Pharmaceuticals
Drug related paraphernalia, e.g., selling bongs, hookahIllegal/synthetic drugs or prescription drugs without a prescription
Financial Services
Unregulated or inadequately licensed financial institutions/money service businessesLending, including Pay-day lendersUnregulated account aggregation
Fortune Tellers
Tarot cards, horoscope readers and psychics
Gambling
- Unlicensed gambling activities
- Unlicensed Binary Options
- Skins/loot box trading
Get-rich-quick Schemes
- Any schemes marketed as get-rich-quick
- Pyramid Schemes
- Multi-level marketing
Regulated Services
- Non-licensed counselling centres
- Unlicensed lawyers or legal services
Speciality Retail
- Counterfeit goods
- Human body parts
- 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 Lifestock
- Stolen Property
- Police-related items
- Mailing lists and personal information
- Government documents and IDs
- Lock picking devices
- Embargoed goods from prohibited countries
Telecommunications
- Illegal telecommunications devices
Timeshare
- Any type of timeshare service/product
5.2 Restricted Business Sectors
Unblock LT 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.
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.
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.)
Claims Institutions
- PPls
- Tax refund services (Must come from an acquirer - no direct customer payments.)
Medical Services
- Non-face-to-face and face-to-face medical services - must come from an acquirer - no direct customer payments
- All other medical-related services
(The following information might be requested in addition to the normal documentation: details about any insurance the merchant has regarding their provision of services, i.e., the liability cover in the event of complications that may occur as a result of procedures, treatment price list, full details of all doctors and nurses registered and operating at the business, including General Medical Council Reference numbers or equivalent, details of license held by practice medical services.)
Ticket Brokers/Agents
Ticket brokers and agencies - must come from an acquirer, no direct customer payments
Real Estate Brokers/Agents
Real Estate Agents and Brokers must be regulated under local AML regulation, such as a supervisory body or by an accountancy body if they are a chartered accountant
(Must come from an acquirer - no direct customer payments. Must be capable of producing CDD/EDD information relating to their customers upon request.)
Computing/Information Technology
- Hardware and Software Sales (including maintenance and repair)
- Computer Programming
- Data Processing
- Integrated Systems
- Design Services (Must come from an acquirer - no direct customer payments)
Nutraceuticals
Websites selling Nutraceutical products (including those with a subscription service) - must clearly outline the name of the company, location, terms of billing and details about cancellation policy
(Must come from an acquirer - no direct customer payments.)
Company Service Providers (CSPs)
- Trust Services
- Company Service Providers
- Asset Managers (Must be regulated under local AML regulation, such as a supervisory body or by an accountancy body if they are a chartered accountant. Must be capable of producing CDD/EDD information relating to their customers upon request. Direct customer Pay-Ins approved only on a case-by-case basis)
Precious Stones/Metals
- Diamonds
- All unregulated Precious Metals - e.g. gold and silver
- High-value Dealers
- Dealers other than diamonds and precious metals Art Dealers
Speciality Retail
Alcohol - must be regulated and have clear policy and controls about age limits
Travel
- Airlines Cruise ships
- Car Hire
- Hotel bookings
Membership Services
Customers must clearly outline on the website, the name of the company, location, terms of billing and details about how to cancel an order or subscription
Contract for Differences (CFDs)
Must be within a licensable jurisdiction.
CFD Brokers licensed from the following jurisdictions must hold an additional license from a more reputable jurisdiction such as within the UK/EEA:
- Mauritius
- South Africa
- British Virgin Islands
- Seychelles
- Bahamas
- St. Vincent and the Grenadines
- United Arab Emirates (where licensing regime forms part of the Free Financial Zones)
- Collection Agencies
- Customers must be well established, reputable and with a history of trading
Financial Services
- Money Service Businesses/Cash Based/Currency Exchange services
- Debit and Credit Cards
(Legal opinion may be requested to support licensing requirements dependent on business model. Subject to full compliance review of policies, procedures and controls.)
Gambling
Gambling operators licensed and operating from an offshore jurisdiction.
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 activityFirearms, 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
No sale of any goods listed in the Unblock LT Prohibited Business Sectors list.The above lists are subject to change from time to time.
6. Transactions
6.1 Prohibited Transactions by Country
Unblock LT 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, Unblock LT is unable to facilitate payments to or from countries list in Section 3.1 Prohibited Jurisdictions, in addition to the following US states
US
- Alabama
- Alaska
- Florida
- Georgia
- Hawai
- Kentucky
- Louisiana
- New York
- New Mexico
- New Jersey
- Nevada
- Oregon
- Ohio
- Washington
- Vermont
6.2 Prohibited Transactions by Business Sector
Unblock LT is unable to process any payments relating to any of the business sectors outlined on its Prohibited Business Sectors List depending on the service/product offered. (refer to Section 5.1}
6.3 Restricted Transactions by Business Sector
Any merchants wishing to facilitate payments to any businesses on the Restricted Business Sectors list (refer to Section 5.2) must notify Unblock LT before offering such services due to partner restrictions. For the avoidance of doubt, this includes customers collecting funds or making payments to merchants in this category and customers opening lined accounts for their customers who operate in these sectors.
