PONTIFI

Terms of Service


Version 1.0 · Last updated 15.09.2026 · Effective from 15.09.2026

These Terms govern the use of the Pontifi platform operated by Pontifi Technologies Inc. They should be read together with the Privacy Policy, the Website Terms of Use and the Risk Disclosure.


1. Introduction

1.1. These Terms of Service (the "Terms") constitute a legally binding agreement between you ("you", "your", or the "User") and Pontifi Technologies Inc., a sociedad anónima incorporated in the Republic of Panama on 6 August 2026, registered with the Public Registry of Panama, Mercantile Section, Folio No. 155788271, with its registered office at Calle 55 Este, Edificio SL55, Piso 21, Oficina 3, Panama City, Republic of Panama (the "Company", "we", "us", or "our"), governing your access to and use of the Pontifi platform, comprising the account areas of https://www.pontifi.io and any related applications, software, APIs, dashboards and tools made available by the Company (collectively, the "Platform"). The public informational pages of https://www.pontifi.io (the "Website") are governed by the Website Terms of Use.

1.2. By registering an account or using the Platform, you confirm that you have read, understood and agree to be bound by these Terms and the Website Terms of Use, and that you have read our Privacy Policy and the Risk Disclosure. If you do not agree to these Terms, you must not register or use the Platform.

1.3. If you use the Platform on behalf of a company or other legal entity, you represent and warrant that you are duly authorised to bind that entity to these Terms, in which case "you" refers to that entity. A User that is a legal entity, or a natural person acting in the course of a trade or profession, is a "business User"; a natural person acting outside a trade or profession is a "consumer".

1.4. "Pontifi" is a trading name of Pontifi Technologies Inc.

2. Nature of the Platform

2.1. The Platform is a technology solution only. The Company is a software and information technology company. The Platform provides a technical interface, an operation and routing layer, and related software tools that enable Users to connect with, and access services offered by, independent third-party service providers ("Partners").

2.2. The Company itself does not provide any financial, payment, banking, money transmission, currency exchange, digital asset, custody, brokerage, investment, credit or similar regulated service, and holds no banking, electronic money, payment institution or virtual asset service provider licence. Any such services accessible through the Platform — including, without limitation, the holding of funds, the issuance of payment cards, the acceptance of payments, the execution of payouts, and the purchase, sale, exchange or custody of digital assets — are provided solely and exclusively by the relevant Partners, acting in their own name, at their own risk, and under their own terms and applicable authorisations.

2.3. Balances, statements, transaction records and similar information displayed in the Platform are records maintained by the Company for your information and reconciliation. They reflect funds and digital assets held by, or transactions executed through, the relevant Partner. The Company operates no account into which Users' funds or digital assets are received; it does not hold, control, transmit or take possession of Users' funds or digital assets at any time, does not accept deposits, and pays no interest on any balance. Balances are not deposits and are not covered by any deposit guarantee or investor compensation scheme. The Company transmits only your instruction to the relevant Partner. If a Partner becomes insolvent or otherwise fails to release funds or digital assets, your claim lies against that Partner and not against the Company.

2.4. The Company is not a party to any transaction, agreement, or relationship between you and any Partner. Your use of a Partner's services is subject to that Partner's own terms and conditions and privacy policy, which you should review before using such services. Where the Partner's terms conflict with these Terms in respect of the Partner's own service, the Partner's terms govern that service.

2.5. The Company does not endorse, guarantee, or assume any responsibility for any Partner or for any services provided by any Partner, including their availability, quality, legality, execution, or outcome.

2.6. Nothing on the Platform constitutes financial, investment, legal, tax, or other professional advice, or an offer or solicitation to buy or sell any financial instrument or digital asset.

2.7. The Company engages only Partners which, to the Company's knowledge, hold the authorisations required for the services they provide through the Platform. The Company does not warrant a Partner's continued compliance.

3. Eligibility and restricted jurisdictions

3.1. To use the Platform, you must: (a) be at least 18 years old (or the age of majority in your jurisdiction, if higher); (b) have full legal capacity to enter into a binding agreement; and (c) not be a Restricted Person as defined below.

3.2. Prohibited persons. The Platform is not offered to, and may not be used by or for the benefit of, any person who: (a) is a citizen or resident of, or is located in, a jurisdiction listed in Part A.1 of Annex 1; (b) is listed on any applicable sanctions or restricted-parties list, or is owned or controlled by, or acting on behalf of, such a person; or (c) is located in any jurisdiction where use of the Platform would be unlawful.

3.3. Jurisdictions where the Platform is not offered. The Platform is not directed at, and is not made available to, persons who are citizens or residents of, or are located, incorporated or have a registered office in, a jurisdiction listed in Part A.2 of Annex 1.

3.4. Persons described in clauses 3.2 and 3.3 are each a "Restricted Person", and the jurisdictions listed in Parts A.1 and A.2 of Annex 1 are the "Restricted Jurisdictions". Annex 1 forms part of these Terms; the version in force at the time of your access applies. The Company may accept a business User established in a jurisdiction listed in Part A.2 only where the relevant Partner has confirmed in writing that it may serve that User under its own authorisations and the Company has agreed to do so in writing; a business User so accepted is not a Restricted Person, and its jurisdiction is not a Restricted Jurisdiction in relation to it, for the purposes of clauses 3.5, 6.2(b) and 13.2(e), for so long as the Partner's confirmation remains in force. You are solely responsible for ensuring that your access to and use of the Platform is lawful in your jurisdiction. By using the Platform, you represent and warrant on a continuing basis that you are not a Restricted Person and are not using the Platform on behalf of a Restricted Person.

3.5. We may use technical means, including geo-blocking and the verification of identity documents, to restrict access from Restricted Jurisdictions, and may suspend or terminate any account that we reasonably believe belongs to, or is used by or for the benefit of, a Restricted Person. Use of a VPN, proxy or other means to conceal your location or to circumvent these restrictions is a material breach of these Terms.

4. Account registration and security

4.1. To use the Platform, you must register an account. You agree to provide accurate, current and complete information during registration and to keep it up to date, and to notify us of any change within ten (10) business days.

4.2. You are responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account. You must notify us immediately at hello@pontifi.com of any unauthorised use of your account or any other breach of security.

4.3. Each User may maintain only one account unless otherwise agreed by us in writing. An account opened by a legal entity may be accessed by such authorised users as that entity designates in the Platform, and that entity remains responsible for all activity carried out under its account, including by authorised users, cardholders and holders of its API credentials, and must revoke access immediately when a person's engagement ends. Accounts may not be sold or transferred, and credentials may not be shared with any person who is not a designated authorised user.

5. Verification, compliance and monitoring

5.1. The Company is not a regulated financial institution. It nevertheless applies the customer due diligence, sanctions screening and transaction monitoring measures set out in its Anti-Money Laundering and Counter-Terrorist Financing Policy, which it is required to apply by contract with its Partners and which are designed to meet the standards those Partners are obliged to apply under their own authorisations. Separately, each Partner applies its own identification, verification and onboarding procedures as a condition of providing its services, and may request information directly from you.

5.2. Before you are permitted to transact, and at any time during the relationship, we may require you to provide: identification documents and, for a legal entity, corporate documents; evidence of the identity of directors and of beneficial owners holding 25 per cent or more; evidence of your address; information on the purpose of the relationship and expected activity; and evidence of the source of funds and, where relevant, source of wealth. We may verify this information through electronic identity verification providers, commercial databases, public registers, sanctions and politically exposed person data, and blockchain analytics.

5.3. You agree that transactions may be delayed, blocked, refused or reversed, and that your account may be suspended, where a verification, screening or monitoring measure so requires. Where we or a Partner are prohibited by applicable law from disclosing the reason for such a measure, it will not be disclosed.

5.4. Funding of, and withdrawals from, your own balance are accepted only from, and released only to, an account, card or wallet held in your own name and demonstrably controlled by you. This clause does not restrict: (a) the receipt by a business User of payments from its own customers through the collection functions of the Platform, including invoices and payment links; (b) payouts initiated by a business User to its own employees, contractors or vendors through the payout functions of the Platform; or (c) transfers between verified Users of the Platform. In each case you must be able to identify the counterparty and provide, on request, the underlying commercial documentation. Cash is not accepted in any form.

5.5. If you fail to provide information requested under this Section within the period stated in the request, we may refuse to establish the relationship, suspend your account, or terminate the relationship in accordance with Section 13.

5.6. For transfers of digital assets you must provide, on request, the information about the originator and the beneficiary that the relevant Partner is required to collect and transmit under the rules applicable to it. A transfer may be delayed or refused until that information is provided.

6. Use of the Platform and prohibited activity

6.1. Subject to these Terms, the Company grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable licence to access and use the Platform for its intended purpose.

6.2. You agree not to, and not to permit any third party to: (a) use the Platform for any unlawful purpose, including money laundering, terrorist financing, proliferation financing, fraud, tax evasion, or the evasion of sanctions or capital controls; (b) use the Platform in or from any Restricted Jurisdiction, or make it available to any Restricted Person; (c) provide false, inaccurate, or misleading information, or conceal the identity of a beneficial owner; (d) use the Platform to act for an undisclosed third party, including as an agent, nominee or payment intermediary, or to serve sub-merchants, unless expressly agreed with us in writing; (e) interfere with, disrupt, or attempt to gain unauthorised access to the Platform, its servers, or networks; (f) reverse engineer, decompile, disassemble, copy, or create derivative works of the Platform, except to the extent permitted by mandatory applicable law; (g) use any robot, scraper, or other automated means to access the Platform without our prior written consent; (h) introduce any viruses, malware, or other harmful code; (i) infringe the intellectual property or other rights of the Company or any third party; or (j) use the Platform in a manner that could damage, disable, overburden, or impair it.

6.3. The Platform may not be used in connection with any activity listed in Part B of Annex 1. Certain activities may additionally be unavailable because of restrictions imposed by our Partners.

6.4. We may establish general practices and limits concerning the use of the Platform, including limits on transactions, integrations, API calls, or data storage, and may modify them at any time.

7. Fees, taxes, conversion and balances

7.1. Fees for the use of the Platform are displayed in the Platform or agreed with you separately in writing. Partners may charge their own fees for their services under their own terms; such fees are outside the Company's control and responsibility.

7.2. Unless expressly stated otherwise, all fees are exclusive of any taxes, duties, or similar charges. You are solely responsible for determining, reporting, and paying any taxes applicable to you in connection with your use of the Platform or of any Partner service.

7.3. We may change our fees by publishing updated fees in the Platform and notifying you by email at least thirty (30) calendar days before the change takes effect. A fee reduction, and a change required by applicable law, by a competent authority or by a Partner, may take effect immediately. If you do not accept a fee increase you may close your account under clause 13.1 before it takes effect; continued use of the Platform after that date constitutes acceptance.

7.4. Currency conversion and swap. Where you use a conversion or swap function, the conversion is executed by a Partner. Rates are quoted by the Partner, are valid only for the period stated in the quote, and incorporate the Partner's spread in addition to any fee disclosed in the Platform. Once you confirm a conversion it cannot be cancelled or reversed. The Company does not set rates, does not act as principal or counterparty to any conversion, and is not liable for rate movement, quote expiry, slippage, or failure or delay in execution by the Partner.

7.5. Negative balances, reversals and set-off. If, as a result of a card transaction, a reversal, a chargeback, a currency conversion, a Partner error or a technical fault, the balance reflected in your account becomes negative, or an amount is credited to you in error, you must repay that amount immediately on demand. You authorise us to instruct the relevant Partner to deduct the amount from any balance reflected in your account, and we may set off any amount you owe us against any amount payable to you. Amounts not repaid within ten (10) business days may result in suspension of your account under clause 13.2 and in recovery of our reasonable costs of collection.

8. Intellectual property

8.1. The Platform, including all software, code, design, text, graphics, logos, trademarks, trade names (including "Pontifi"), databases, and other content, is owned by or licensed to the Company and is protected by intellectual property laws. Except for the limited licence granted in clause 6.1, no rights in or to the Platform are granted to you.

8.2. You may not use the Company's or Pontifi's name, logos, or trademarks without our prior written consent.

8.3. If you provide us with any feedback or suggestions regarding the Platform, you grant us a perpetual, irrevocable, worldwide, royalty-free right to use such feedback without restriction or compensation.

9. Third-party services and content

9.1. The Platform may contain integrations with, links to, or content from Partners and other third parties. Such integrations, links, and content are provided for convenience only and do not constitute an endorsement by the Company.

9.2. Any dealings between you and any Partner or other third party, including the delivery of and payment for services, and any other terms, conditions, warranties, or representations associated with such dealings, are solely between you and that Partner or third party. Claims relating to Partner services must be addressed directly to the relevant Partner.

10. Disclaimers

10.1. THE PLATFORM IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, AVAILABILITY, ACCURACY, OR UNINTERRUPTED OR ERROR-FREE OPERATION.

10.2. WITHOUT LIMITING THE FOREGOING, THE COMPANY DOES NOT WARRANT OR ASSUME ANY RESPONSIBILITY FOR: (A) ANY SERVICES PROVIDED BY PARTNERS OR OTHER THIRD PARTIES; (B) THE EXECUTION, TIMING, OR OUTCOME OF ANY TRANSACTION EFFECTED THROUGH PARTNER SERVICES; (C) ANY LOSS OF FUNDS OR DIGITAL ASSETS HELD WITH, OR PROCESSED BY, ANY PARTNER; OR (D) THE CONTINUED VALIDITY OF ANY LICENCE, AUTHORISATION OR REGISTRATION HELD BY A PARTNER, OR THE REGULATORY TREATMENT OF A PARTNER'S SERVICES IN ANY PARTICULAR JURISDICTION.

10.3. YOU ACKNOWLEDGE THAT DIGITAL ASSETS ARE VOLATILE, THAT TRANSACTIONS IN DIGITAL ASSETS ARE GENERALLY IRREVERSIBLE, THAT A TRANSFER TO AN INCORRECT ADDRESS CANNOT BE RECOVERED, AND THAT ANY DECISION TO USE PARTNER SERVICES INVOLVING DIGITAL ASSETS IS MADE SOLELY AT YOUR OWN RISK. THE PRINCIPAL RISKS ARE SUMMARISED IN THE RISK DISCLOSURE PUBLISHED ON THE WEBSITE, WHICH YOU SHOULD READ BEFORE USING ANY DIGITAL-ASSET FUNCTION.

11. Limitation of liability

11.1. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY AND ITS AFFILIATES, DIRECTORS, OFFICERS, EMPLOYEES, AND AGENTS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF PROFITS, REVENUE, DATA, GOODWILL, OR BUSINESS OPPORTUNITY, ARISING OUT OF OR IN CONNECTION WITH THESE TERMS OR THE USE OF (OR INABILITY TO USE) THE PLATFORM, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

11.2. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE AGGREGATE LIABILITY OF THE COMPANY ARISING OUT OF OR IN CONNECTION WITH THESE TERMS OR THE PLATFORM SHALL NOT EXCEED: (A) WHERE YOU ARE A CONSUMER, THE GREATER OF THE TOTAL FEES PAID BY YOU TO THE COMPANY IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM AND FIVE HUNDRED US DOLLARS (USD 500); AND (B) WHERE YOU ARE A BUSINESS USER, THE GREATER OF THE TOTAL FEES PAID BY YOU TO THE COMPANY IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM AND ONE THOUSAND US DOLLARS (USD 1,000).

11.3. Nothing in these Terms excludes or limits liability that cannot be excluded or limited under applicable law, including liability for fraud or wilful misconduct.

12. Indemnification

12.1. You agree to indemnify the Company and its affiliates, directors, officers, employees and agents against any third-party claim, and any liability, damages, losses, costs and expenses (including reasonable legal fees) finally awarded or agreed in settlement, arising out of: (a) your breach of these Terms; (b) your violation of any applicable law or of the rights of any third party; or (c) any content or personal data you submit to the Platform. The Company will notify you promptly of any such claim, will not settle it without your prior written consent (not to be unreasonably withheld), and will permit you to assume its defence with counsel reasonably acceptable to the Company. This indemnity does not apply to the extent the claim arises from the Company's own breach, negligence or wilful misconduct.

13. Suspension and termination

13.1. You may stop using the Platform and close your account at any time by contacting us at hello@pontifi.com. Closure does not affect obligations accrued before closure.

13.2. We may suspend, restrict, or terminate your access to the Platform, in whole or in part, at any time and without prior notice, if: (a) we reasonably believe you have breached these Terms; (b) we are required to do so by applicable law, by a competent authority or by a Partner; (c) we reasonably suspect fraud, money laundering, sanctions breach, other unlawful activity, or a security risk; (d) you fail to provide information requested under Section 5; (e) you are or become a Restricted Person; or (f) we discontinue the Platform or any part of it, in which case clause 15.2 applies.

13.3. Where an account is suspended or terminated, any balance reflected in the Platform will be released by the relevant Partner, on your request and on our technical instruction, to an account, card or wallet held in your own name that meets the requirements of clause 5.4, save where the Partner or the Company is prevented from doing so by applicable law, by an order of a competent authority, or by the Partner's own terms. The Company gives no undertaking as to the timing of any release.

13.4. Upon termination, your licence to use the Platform ceases immediately. Sections which by their nature should survive termination (including Sections 2, 5, 7, 8, 9, 10, 11, 12, 14, 16, 17 and 18, and clause 13.3) shall survive.

14. Complaints

14.1. If you are dissatisfied with the Platform, please contact us at hello@pontifi.com with a description of the matter, your account details and any supporting documents. We will acknowledge your complaint within five (5) business days and provide a substantive response within thirty (30) calendar days, or inform you of the reason for any delay.

14.2. Complaints concerning a service provided by a Partner must be addressed to that Partner under its own complaints procedure. On request we will identify the relevant Partner and provide its contact details.

15. Changes to the Terms and the Platform

15.1. We may amend these Terms by publishing an updated version in the Platform and notifying you by email at least thirty (30) calendar days before the change takes effect. Changes required by applicable law, by a competent authority or by a Partner, changes necessary to address a security risk, and changes that are wholly to your benefit, may take effect immediately. If you do not agree with the updated Terms, you may close your account under clause 13.1 before they take effect; continued use of the Platform after that date constitutes acceptance.

15.2. We may modify, suspend, or discontinue the Platform or any feature of it at any time. Where a change materially reduces functionality you use, or the Platform is discontinued, we will give you reasonable notice where it is practicable to do so.

16. Governing law and dispute resolution

16.1. These Terms, and any dispute or claim arising out of or in connection with them or the Platform (including non-contractual disputes or claims), shall be governed by and construed in accordance with the laws of the Republic of Panama, without regard to its conflict of laws rules.

16.2. Any dispute, controversy, or claim arising out of or relating to these Terms or the Platform that cannot be resolved amicably within thirty (30) calendar days of written notice shall be finally settled by arbitration administered by the Centre for Conciliation and Arbitration of Panama (Centro de Conciliación y Arbitraje de Panamá, CeCAP) in accordance with its rules in force at the time of filing. The seat of arbitration shall be Panama City, Republic of Panama. The arbitration shall be conducted by one (1) arbitrator and in the English language. The award shall be final and binding on the parties.

16.3. Nothing in clause 16.2 prevents either party from applying to any court of competent jurisdiction for interim or injunctive relief, from bringing a claim for infringement or misuse of intellectual property, or from bringing a claim for a sum not exceeding USD 25,000 before the ordinary courts of the Republic of Panama.

16.4. Where you are a consumer, clause 16.2 applies only to the extent permitted by the law of the Republic of Panama, including Law 45 of 31 October 2007, and by any mandatory consumer protection law of your country of residence. Nothing in these Terms deprives you of the protection of provisions from which you may not derogate by agreement, or of your right to bring proceedings before the Authority for Consumer Protection and Defence of Competition (ACODECO).

17. Miscellaneous

17.1. Entire agreement. These Terms, together with the Privacy Policy, the Website Terms of Use, any separate written agreement referred to in clause 18.1, and any other documents expressly incorporated by reference, constitute the entire agreement between you and the Company with respect to the Platform and supersede all prior agreements and understandings.

17.2. Assignment. You may not assign or transfer these Terms or any rights or obligations hereunder without our prior written consent. We may assign these Terms without restriction, including in connection with a merger, acquisition, or sale of assets.

17.3. Severability. If any provision of these Terms is held invalid or unenforceable, the remaining provisions shall remain in full force and effect, and the invalid provision shall be replaced by a valid provision that most closely reflects its intent.

17.4. No waiver. Our failure to enforce any provision of these Terms shall not constitute a waiver of that or any other provision.

17.5. Force majeure. The Company shall not be liable for any failure or delay in performance resulting from causes beyond its reasonable control, including acts of God, natural disasters, war, terrorism, civil unrest, labour disputes, governmental actions, power or internet failures, or failures of third-party services.

17.6. No partnership. Nothing in these Terms creates any partnership, joint venture, agency, fiduciary, or employment relationship between you and the Company.

17.7. Language. These Terms are drawn up in the English language. Any translation is provided for convenience only; in case of discrepancy, the English version prevails.

17.8. Notices. We may provide notices to you via the Platform or by email to the address associated with your account; notices of changes under clauses 7.3 and 15.1 will be given by email. Notices to the Company should be sent to hello@pontifi.com.

18. Business Users and cards

18.1. Where the User is a business User, these Terms apply subject to any separate written agreement executed between that User and the Company, which prevails in case of conflict.

18.2. Cards made available through the Platform are issued by a licensed Partner and are subject to that Partner's cardholder terms and to the operating rules of the relevant card scheme, including those governing authorisation, disputes, chargebacks and reversals. Disputes concerning a card transaction must be raised through the process notified in the Platform within the time limits set by the card scheme. The Company is not the issuer, has no authority to grant or refuse a chargeback or refund, and acts only as a technical channel for the dispute.

19. Contact

Pontifi Technologies Inc., a sociedad anónima incorporated in the Republic of Panama on 6 August 2026, registered with the Public Registry of Panama, Mercantile Section, Folio No. 155788271.

Registered office: Calle 55 Este, Edificio SL55, Piso 21, Oficina 3, Panama City, Republic of Panama

General and support: hello@pontifi.io

Compliance and data protection: compliance@pontifi.io

Website: https://www.pontifi.io

Annex 1 — Restricted jurisdictions and prohibited activities

This Annex forms part of these Terms. The Company may update it from time to time. An update takes effect immediately where it is required by sanctions, by applicable law, by a competent authority or by a Partner; any other update takes effect on the notice period set out in clause 15.1.

Part A — Jurisdictions

A.1. Prohibited jurisdictions. No User is accepted and no transaction is processed where the person is a citizen or resident of, or is located in, a jurisdiction subject to comprehensive sanctions or embargoes administered by the United Nations, the United States, the European Union or the United Kingdom, or a jurisdiction the Company prohibits under its own risk appetite. As at the date of these Terms these are: Iran, the Democratic People's Republic of Korea, Cuba, Syria, and Crimea together with the non-government-controlled areas of the Donetsk, Luhansk, Zaporizhzhia and Kherson regions of Ukraine; together with the jurisdictions named on the FATF list of High-Risk Jurisdictions subject to a Call for Action (currently Iran, the Democratic People's Republic of Korea and Myanmar).

A.2. Jurisdictions where the Platform is not offered. The United States of America and its territories, the member states of the European Union and of the European Economic Area, and the United Kingdom. A business User established in one of these jurisdictions may be accepted only on the terms set out in clause 3.4. Pending a decision of the Company's Board of Directors, persons who are citizens or residents of, or are located, incorporated or have a registered office in, the Russian Federation are not onboarded; the exception in clause 3.4 does not apply to the Russian Federation.

A.3. Higher-risk jurisdictions. A User connected with a jurisdiction named on the FATF list of Jurisdictions under Increased Monitoring, a jurisdiction identified by the European Commission as a high-risk third country, or a jurisdiction restricted by a Partner, may be accepted only following enhanced due diligence and the Company's approval.

Part B — Prohibited activities

The Platform may not be used in connection with:

  • darknet marketplaces, ransomware, mixing or tumbling services and other services designed to obscure transaction provenance;

  • unlicensed money services businesses, unlicensed exchanges and unlicensed gambling;

  • the production of or trade in illegal drugs, weapons, human trafficking or child sexual abuse material;

  • counterfeit goods;

  • adult services, pharmaceuticals, forex and binary options, investment or credit services, fundraising, precious metals and cash-out services, except where the activity is carried on under a valid licence disclosed to and accepted by us in writing;

  • Ponzi, pyramid or other schemes whose purpose is to defraud third parties;

  • any activity that is unlawful in the jurisdiction of the User or in the Republic of Panama.