Subscript
This Customer Acceptance Policy ("Policy") sets out the principles and rules governing the onboarding and continued relationship with clients using virtual IBAN (vIBAN) services. The goal is to mitigate regulatory, compliance, and reputational risks by establishing clear criteria for client eligibility.
Clients with direct or indirect links to the following countries are strictly prohibited from being onboarded. This includes companies registered, operating, or having UBOs currently residing in or holding citizenship from these jurisdictions.
However, the place of birth or former citizenship alone shall not constitute a disqualifying factor, provided that the UBO holds a valid residence permit or citizenship in an eligible jurisdiction and passes enhanced due diligence.
-Abkhazia
-Afghanistan
-Albania
-American Samoa
-Anguilla
-Antigua and Barbuda
-Aruba
-Bahamas
-Barbados
-Belarus
-Bermuda
-British Virgin Islands
-Burkina Faso
-Burundi
-Cambodia
-Cayman Islands
-Central African Republic
-Congo, the Democratic Republic
-Cook Islands
-Crimea
-Cuba
-Curacao
-Fiji
-Guam
-Guinea
-Guinea Bissau
-Haiti
-Iran, Islamic Republic of
-Iraq
-Jamaica
-Jordan
-Libya
-Mali
-Marshall Islands
-Morocco
-Myanmar
-Nagorno-Karabakh
-Nicaragua
-Northern Cyprus
-North Korea
-Pakistan
-Palau
-Panama
-Philippines
-Russian Federation
-Samoa
-Sahrawi Arab Democratic Republic
-Senegal
-Seychelles
-Somalia
-South Sudan
-St Kitts & Nevis
-St Lucia
-St Vincent & Grenadines
-Sudan
-Syria
-Trinidad & Tobago
-Turks & Caicos
-Uganda
-Ukraine
- United States of America
- United Kingdom (in accordance with the FPR regulation)
-United States Virgin Islands
-Vanuatu
-Venezuela
-West Bank
-Yemen
-Zimbabwe
Additional countries classified as High Risk by FATF, the EU, or the UK may be subject to enhanced due diligence or rejection based on case-by-case assessment.
The following industries are prohibited regardless of licensing status:
- Anonymous accounts
- Private banking
- Downstream correspondent banking
- Financial Services. Companies which business line consists of payment services, crypto exchange and other activities that may be subject to "nesting"
- Cash
- Companies registered in Offshore Business Centres/tax havens
- Casinos/Gambling industry entities that do not have proper licence or are licensed outside of EEA
- Sanctioned persons and businesses, as well as where the sanction risk is very high
- Companies engaged in pharmacy/food supplements
- Companies with incorporation form LP/LLP
- Other entities whose activity and fund flow have lack of economic meaning (eg: suspected shell companies)
- Arms, defence, military, atomic power
- Charities
- CFD / Forex
- Synthetic stimulants
- Illegal Drugs; Illegal Sale of Prescription Drugs
- Entities that business line consists of trading with Cannabis/ CBDs
- Bestiality, Rape, Pornography
- Non-Government Organisations
- Trusts and similar arrangements
- Multi-level marketing
- Crowdfunding
- ICO’s (Initial Coin Offering), IEO’s (Initial Exchange Offering), STO’s (Security Token Offering)
- Unlicensed service providers
- Merchants included in Visa and MasterCard blacklists
- Marketing Lead Generation
- Online Education
- Alcohol businesses, tobacco, smoking supplies, e-cigarettes, e-liquids, vaping liquid, vaping accessories
- Wildlife Trafficking
- Atomic power, oil, gas and shipping companies
- Corporate service provider and other legal and accounting services
- High-value dealers (art dealers and galleries, auction houses, precious metals and stones, antiques, other valuable commodities, and other merchants dealing with high-value goods)
A client may submit onboarding applications as part of a group of affiliated companies (e.g. MSB and VASP entities) that are under common control or ownership. In such cases, the group will be treated as a single client for the purpose of onboarding, provided this structure is clearly disclosed in writing.
Onboarding of multiple related entities for the purpose of regulatory circumvention (e.g. EU restrictions) is not permitted unless properly justified and transparent. The Company reserves the right to request supporting documentation regarding intra-group ownership and business justification.
Corporate customers must provide:
1. Registration/Incorporation Details of Corporate Customer
2. Document details (Name/Surname/Document Number of UBO etc)
3. Address details
4. Information about ultimate Beneficial Owner/significant control over 25% / if UBO is a legal entity or a physical person
5. Ultimate Beneficial Owner(s) details
6. Other details - business activity description and any other relevant information (website etc.)
7. Description of customer’s business partner
8. Description of customer’s fund flow using Clear Junction services
9. Any adverse information about customer/related person/business partner
10. Compliance overall evaluation
11. Other details
All customer applications will be reviewed by the compliance team. Applications may be approved, rejected, or returned with additional questions. No services will be provided until full due diligence is completed.