Prohibited & Restricted Businesses

This list sets out who may not use the platform at all, who may use it only on conditions, and which countries and territories we will not deal with. It forms part of the Terms of Service. The Acceptable Use Policy governs how a permitted business must behave; this list governs who may use the platform in the first place.

1. Prohibited businesses

These may not use the platform, whatever their conduct:

• unlicensed weapons, ammunition, explosives or military equipment;
• controlled substances or narcotics, and equipment for producing or concealing them;
• unlicensed gambling or betting;
• unlicensed money services, payment intermediaries, currency exchanges or crypto-asset exchanges;
• pyramid schemes, Ponzi schemes, recruitment-based multi-level marketing and unregistered investment products;
• adult services and sexually explicit content;
• shell arrangements built to hide the true owner of funds from our checks;
• businesses established in, controlled from, or operating out of a layer-one jurisdiction under clause 3.

2. Restricted businesses

These may use the platform only after additional checks and on conditions we set case by case: dealers in precious metals, precious stones or other high-value goods; businesses that hold or handle third-party funds; virtual asset service providers and other regulated financial businesses; charities and non-profits with cross-border grant flows; defence and dual-use exporters; and any sector we assess as higher risk for financial crime. We may decline any of these where the risk is too high for us.

3. Restricted jurisdictions — layer one: not served

3.1 We do not onboard a customer that is established in, controlled from, or operating out of the following, and we do not process a transfer with a payer, payee, correspondent or underlying counterparty there:

• Belarus
• Cuba
• Iran
• Myanmar
• North Korea (DPRK)
• Russian Federation
• Syria
• the non-government-controlled areas of Ukraine, being Crimea and the Donetsk, Luhansk, Kherson and Zaporizhzhia regions

3.2 Layer one is applied automatically and is not open to negotiation, an exemption or a case-by-case assessment. It reflects comprehensive sanctions regimes together with our own decision not to carry the residual risk in the remaining cases, and it can be wider than any single sanctions regime requires.

3.3 We may add a jurisdiction to layer one at any time, with immediate effect where a sanctions measure requires it. A jurisdiction added to layer one while you are a customer is treated as a change under clause 25 of the Terms of Service, except where an immediate measure is required by law.

4. Restricted jurisdictions — layer two: enhanced checks and a decision

4.1 A jurisdiction is layer two where any of the following applies:

• it is on the European Union’s list of high-risk third countries  for anti-money-laundering purposes;
• the Financial Action Task Force names it in its statement on high-risk jurisdictions subject to a call for action, or in its list of jurisdictions under increased monitoring;
• it is subject to targeted or sectoral measures under EU , UN , US , UK or Swiss  measures that are relevant to the business or the transfer; or
• our own risk assessment places it there, for reasons including corruption indices, the strength of the local supervisory regime, Partner coverage, or our experience of the corridor. All sources linked in this clause were retrieved on 19 August 2026.

4.2 For a layer-two jurisdiction we apply enhanced due diligence: additional verification of the business, its owners and its controllers; documentary evidence of the source of funds and of the commercial purpose of the corridor; confirmation of the counterparty; and, where appropriate, transaction limits, a lower approval threshold or a requirement to pre-notify individual transfers.

4.3 Layer two is a decision, not an automatic block. We may accept the business on conditions, accept it for some corridors and not others, or decline it. We are not obliged to explain a decision where the law, a regulatory requirement, a confidentiality obligation or an ongoing investigation prevents us.

4.4 A Partner may decline a layer-two jurisdiction even where we would accept it. Where that happens the corridor is unavailable, whatever our own assessment.

5. How we apply the two layers

5.1 We test both establishment and connection. The tests are the customer’s place of establishment and effective management, the residence and nationality of its beneficial owners and controllers, the payer and payee of each transfer, any correspondent or intermediary in the chain, and the currency corridor itself.

5.2 Screening runs at onboarding, at each re-verification and on every transfer. A change in your ownership, control or corridor mix can move you between layers, which is why clause 8.2 of the Terms of Service requires you to tell us when any of it changes.

5.3 Routing your business through a third country does not take it out of a layer. We assess where the money and the control actually come from and go to, not only what the paperwork says.

6. Where the current lists live

6.1 Layer one is the list in clause 3.1 and is maintained here. Layer two is defined by reference to the sources linked in clause 4.1, as they stand at the time of the assessment. The sanctions and high-risk lists themselves are not reproduced here; the links in clause 4.1 lead to the current versions.

6.2 Every change to clause 3.1 is recorded in the Versioned Terms Archive & Change Log with the date it took effect.

7. How we apply and update this list

7.1 This list is not exhaustive. We may add categories that create legal, regulatory, financial-crime, operational or reputational risk.

7.2 If you are unsure whether your business or a corridor is affected, contact compliance@cashxchain.com before onboarding.