Prohibited Business

Written by

Prohibited Business and High-Risk Business Policy
Version 4.0

Purpose
As an Authorized Payment Institution, we are considered to be at potentially higher risk for money laundering and terrorist financing activities. The purpose of this document is to give all staff at AB Money guidance and remind them of their obligations under The Money Laundering, Terrorist Financing and Transfer of Funds(Information on the Payer) Regulations 2017, Proceeds of Crime Act and Terrorism Act 2000 as set out in the AML Policy. Including the update, the UK's AML regime to incorporate international standards set by the Financial Action Task Force (FATF) and to transpose the EU’s 5th Money Laundering Directive.

The document and its activity may be subject to change and will undergo a periodic compliance review to ensure adherence to the aforementioned. The Company reserves the right to vary, change, alter, amend, add to or remove any of the terms and conditions of this procedure at any time.

Scope
This document details the information and tools in the identification of clients both private and corporate, and beneficiaries that will need to be referred to compliance for approval. Thisis because they are prohibited.

This document lists Industries or items and activities that AB MONEY prohibits working with as it is outside of the Company’s Risk Appetite. It applies to any person or entity using our payment service and any transactions that we are asked to process.

If we believe or suspect that any transaction violates this policy or is otherwise illegal or unsuitable, we may take any corrective action that we deem appropriate, including blocking the transaction, holding funds associated with a prohibited transaction, suspending, or restricting the use of our service, terminating the accounts of violators, or any other corrective action.

Core Obligations
It is the policy of AB Money to strictly comply with all laws and regulations that apply to any of their activities and operations, or that may give rise to the risk of liability for any of their branches or employees.

It is the duty of all employees to abide by all applicable laws and regulations, and exercise great care not to take or authorize any actions that may create even the appearance of illegal conduct or other impropriety. Staff must not try to falsify the truth or chose not to divulge information, in order to benefit themselves or the customers – this is an illegal offence and the company’s staff, who violate this Policy will be subject to appropriate action.

Prohibited Business
Although there are sanctioned countries that Financial Institution partners will not allow us to facilitate payments to (directly or indirectly) and we screen against various Financial Sanction lists - which the Company will not transfer funds to and have the appropriate controls in place to prohibit. The Company documents its prohibited business list along with its ‘Compliance Approval Required’ so that Compliance can monitor what types of industries are coming to AB Money which may have an impact the Risk Assessment of the firm.

Any item that features on the following list MUST be submitted to the MLRO who will review and respond on how to continue before either a business relationship is approved, or a payment is released.

Countries
For a list of counties that are considered to be higher risk/prohibited, these are listed with the risk rating of “Needs MLRO’s Approval”.

If a client tries to register or pay to any of these listed the transaction will be auto referred to compliance and it put in review required status in AB Money monitoring system (firewall) - where no further action can be taken by anyone except the MLRO.

Prohibited Industries

Industry Risk
 Gambling Prohibited
 Pornography and Adult Prohibited
 MSBs (unregistered or non-regulated) Prohibited
 Shell companies [organizations with no physical presence, or meaningful decision making and / or management] Prohibited
 Unregistered Charities Prohibited
 Any business linked to trading active arms and Lethal Weapons Prohibited
 Anything related to illegal drugs (as defined in the UK), including, for the avoidance of doubt, drug paraphernalia Prohibited
 Binary options trading Prohibited
 Crowd funding Prohibited
 Remittances funded in cash; Cash and Check Handling: Check Cashing, Deposit Taking, Cash Transfer Prohibited
 Private security firms Prohibited
 Pay day lenders Prohibited
 Diamond and precious metal merchants, including jewelers Prohibited
 Debt management and collection Prohibited
 Gaming Prohibited
 Cultural Artifacts and Art Dealers Prohibited
 Political and Religious Organizations Prohibited

 

High Risk Business Industries and Individuals

The following businesses/individuals are deemed to be higher risk by the business and will need EDD to be performed. The MLRO will advise the onboarding team as needed / requested, on a case-by-case basis, the appropriate and required action to take.

Industry Risk
 Banking & capital markets High Risk
 Financial Services (excluding MSB) High Risk
 Shipping Services High Risk
 Consulting High Risk
 Government & public sector High Risk
 Oil & gas High Risk
 Asset & wealth management High Risk
 Metals High Risk
 Pharmaceuticals & life sciences High Risk
 Registered Charities(includes Non-Profits Organizations, Non-Governmental Organizations (NGOs)) High Risk
 Chemicals High Risk
 Bitcoin and other Cryptocurrencies High Risk
 Mining High Risk
 Private equity High Risk
 Real estate High Risk
 Dealers in high value goods(such as precious metals including precious stones) High Risk
 Fireworks and related goods High Risk
 Jewelers High Risk
 Anything linked to military contracts. (Note – if also linked to Lethal Weapons, then this becomes prohibited) High Risk
 Cultural Artifacts and Art Dealers High Risk
 Ivory or other items related to protected species, or archaeological, historical, religious significance of rare scientific value High Risk
 Tobacco products High Risk