Accepted Business

As a general principle, Volume shall not onboard merchants carrying out businesses or activities that are illegal, conducted in absence of required licences or permissions, or present an excessive reputational risk (which includes any material adverse media) for Volume. Volume's merchant's underlying customers must also comply with this requirement.

In general, Volume will not do business with groups, legal entities, bodies, and similar which have been sanctioned for major offences irrespective of when the Merchant was sanctioned and the jurisdiction(s) in which it was sanctioned.

Note: Within this document, "Merchants" are noted to provide goods and services to their underlying customers.

This implies, inter alia, that:

• As required, Merchants must hold the appropriate licences or permissions to operate and provide services/sell goods in their countries/territories of establishment, and in the countries/territories they provide services or sell goods to;
• As required, products and services sold or provided by Volume's merchants (and their underlying customers) must comply with applicable legal or regulatory standards.

Prohibited Merchant Types and Prohibited Payment Flows:

Volume does not permit pay in or pay outs from its accounts in physical cash. Volume does not onboard, nor will it process the payment flows for its Merchants, for the following:

• Groups, legal bodies or similar subject to international sanctions or embargoes, in particular as issued by the Commission de Surveillance du Secteur Financier ("CSSF"), HM Treasury (UK), the European Union ("EU"), the United Nations ("UN") or the US Office of Foreign Assets Control ("OFAC");
• "Non-standard" or "non transparent" activities - those carried out through special-purpose or assimilated legal entities (special purpose vehicles) (structures) or in jurisdictions that impede transparency or which do not meet international banking standards;
• Bidding fee auctions, penny auctions, or any type of all-pay auction in which all participants must pay a non-refundable fee to place each small incremental bid;
• Shell banks; (banks based in countries where they have no physical presence involving decision-making and management and which are typically not connected to wider regulated financial groups);
• Shell companies; (a company with no physical presence involving effective decision-making, operations or assets other than cash or equivalents of cash);
• Bearer share corporations and companies connected to nominee or similar arrangements for the purpose of hiding or mask the true beneficial ownership (some trust structures may be permitted, depending on the merits of the case and there is no suggestion of untoward behaviour);
• Physically present Adult Services - this includes, but is not limited to, Escort services, Solicitation thereof, sale and/or advertising or suggestion of any physical sexual services that may imply or suggest prostitution, regardless whether it is legal in the specific country involved;
• Unregulated or offshore holding/investment companies involved in managing or investing own- or third-party funds (This does not include regulated investment companies or regulated investment funds in Countries permitted for Correspondent Banking relationships);
• Any involvement in the sale or marketing of Binary Options;
• Weapons of war, automatic weapons, ammunition or defence equipment: Includes merchants involved in the sales, intermediation or commerce of war or automatic weapons, including but not limited to chemical weapons, cluster bombs, ammunition, or other defence equipment or similar.

Volume's restrictions on directly on boarded Merchants:

Volume's merchants may fall under the following categories, subject to additional due diligence and approvals:

• Adult services that are not physically present, this includes dating sites, websites with adult content or products, and pornography businesses. If any payments are to be made to, or received from, a business providing these services the following restrictions also apply. These businesses must:
  • Have no suggestions of escort services, or the sale of physically present sexual services (solicitation/prostitution);
  • Have no material negative media which could result in material reputational damage for Volume; and
  • Be incorporated within the UK, or Europe.
• Any business involved with Cannabidiol "CBD". These businesses must:
  • Be able prove that the Tetrahydrocannabinol "THC" content is within legal limits, and prove that this is continually monitored and tested;
  • Possess the appropriate licences in those jurisdictions where they are established, or sell products into; and
  • Have the appropriate onboarding procedures and controls to address the risks associated with this Business type. These procedures and controls may be assessed by Volume before approval to proceed is provided.
• Charities, social service organisations and other non-profit or political organisations. These businesses must:
  • Be registered, or local equivalent, in the country of incorporation;
  • Not be located in high-risk countries (as defined by Volume), and must not use Volume for payments from any restricted countries;
  • Not sponsor or support any act of violence or hate
• Holding companies of private individuals.

Restricted Client Types:

Volume has placed restrictions on the Merchant types listed below.

The Merchant types and restrictions are:

• Affiliate Marketing schemes, including network marketing, referral marketing, multi level marketing. These businesses must:
  • Not be established as a multilevel scheme for the purpose of circumventing credit card schemes rules;
  • Comply, in letter and in practice, with distant marketing or online selling legislation, including US negative option features and EU withdrawal rights, or equivalent;
  • Not engage in aggressive tax planning or transfer pricing, make use of nominees or similar structures to hide or mask true beneficial ownership of the entities involved in the scheme;
  • Not have unfair pricing or charges, or withdrawal / cancellation rights that cannot be effectively exercised without unfair costs or penalties.
• Corporate service provider and other legal and accounting services. These businesses must:
  • Have licensing/registration in the countries
• Virtual Currencies / Crypto Asset firms (i.e. firms engaged in exchange services between virtual currencies and fiat currencies). These businesses must:
  • Be registered / authorised and under supervision by a competent authority in the UK/EEA or in countries approved for Correspondent Banking relationships and comply with FATF recommendation relevant for virtual currencies;
  • The experience of the senior management and leadership team must be of an acceptable risk profile, including the experience and qualifications of the MLRO; Compliance team and Onboarding team. (The MLRO, Compliance team and Onboarding team must not have any conflicts of interest, for example they should be independent of any income generating departments);
  • Not offer any privacy coins or any encrypted transactions adding anonymity. The list of prohibited products is maintained by the Compliance department of Volume;
  • Have in place appropriate transaction monitoring tools, which includes identifying signs of mixers/tumblers. These tools must be deemed satisfactory upon review to be accepted and ratified by Volume's Compliance department. An expectation is that the monitoring must have solid Know Your Transaction ("KYT") methodologies.
  • Be serviced by the relationship personnel designated as being able to support Virtual Currencies/Cryptoasset Clients.
• Blockchain-related projects that are not VASPs i.e., does not provide regulated activity in the jurisdiction they operate in can be onboarded as corporate client subject to enhanced due diligence
• Pharmaceuticals (includes any drug paraphernalia, pseudo-pharmaceuticals, and any other associated product, service or equipment.) These businesses must:
  • Possess the appropriate licences in those jurisdictions where they are established or sell products into.
• Adult content
• Facilitation, sale or distribution of weapons/firearms, ammunition, military or semi-military goods, military software or technologies and related products
• Unlicensed/unregulated gambling, casinos or betting establishments
• Businesses which allow licensed or unlicensed internet gambling
• Unlicensed foreign exchange services, such as exchange houses, money transmitters, money transmission agents
• Unregistered fund-raising activities
• Ponzi-schemes, any pyramid selling and multi-level marketing
• Violence related activities, including the creation, facilitation, sale, or distribution of any material that promotes violence or hatred
• Political groups/parties, religious organizations
• Shell Banks or unlicensed banks;
• Digital Currency Providers;
• Drugs, and drug paraphernalia, excluding CBD (cannabidiol) - which may be dealt with on a case by case basis.
• Entities that are Prohibited Parties:
  • 25% or more owned or otherwise Controlled by:
    • Sanctioned Parties or an Entity Subject to Sectoral Sanctions; or
    • Entities that are incorporated or located in a Sanctioned Country or Territory,
  • Individuals who are resident in a Sanctioned Country or Territory
  • Entities that are incorporated or located in a Sanctioned Country or Territory
  • Individuals who are resident in a Sanctioned Country or Territory
  • Individuals who hold more than 70% of their assets in a Sanctioned Country or Territory
  • Entities or Individuals that have direct or indirect dealings with sanctioned Countries or Territories
• Individuals or entities that are prohibited due to Dual Use Goods ("DUG") that can not be established that they are for civil purposes only.
  • Nuclear materials
  • Materials, chemicals, micro-organisms, and toxins
  • Materials used for processing
  • Electronics
  • Computers
  • Telecommunications and information security
  • Sensors and lasers
  • Navigation and avionics
  • Marine
  • Aerospace and propulsion
• Individuals or entities that are known or strongly suspected of involvement in Money Laundering or Terrorist Financing. This includes Tax Evasion (which is a predicate offence to money-laundering), insider trading, market manipulation, as well as corruption offences, drug dealing and organised crimes;
• Individuals or entities who wish to establish anonymity through numbered accounts or other means, including fictitious names;
• Individuals who are fronting for another individual who is the actual Beneficial Owner;
• Clients who have been the subject of three (3) or more SARs within a twelve (12) month period
• Entities with unduly complex structures (see Section 5.3 below);
• Individuals or entities who fail to comply with the Get Volume's AML Procedures and these Procedures.
• Gambling. These businesses must:
  • Be incorporated in one of the following jurisdictions: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Gibraltar, Greece, Greenland, Hungary, Isle of Man, Italy, Latvia, Malta, Poland, Portugal, Romania (subject to the business holding 2nd Class Gambling licence), Spain, Slovakia, Sweden and United Kingdom. Additional countries may only be accepted with explicit approval from Volume's Compliance department;
  • Only perform the following activities: online gambling, betting, poker, sport, horse racing, skill games (except for Portugal where such activity is prohibited), casino, lottery, arcade;
  • Have a relevant licence (as required) where they are established or provide services to, including by means of a website in a country-specific language;
  • Be registered on the local countries gambling commission;
  • Be subject to European MLDs or UK equivalent;
  • Offshoring gambling (in short term)
  • Have no material negative media which could result in material reputational damage for Volume.

In addition to the above, the Gambling Client must:

• Be established more than five years;
• Be serviced by the relationship personnel designated as being able to support gambling Clients.

• Import/export and cross-border logistics companies including maritime and land based shipping. These businesses:
  • Must exercise supply chain due diligence to ensure that recipients and counterparties to a transaction are not sending or receiving commodities that may trigger sectoral sanctions.
  • May not have activities involving countries considered prohibited by Volume,
  • May not deal with goods or counterparties considered prohibited by Volume.

If a Merchant wishes to process transactions through Volume for customers in the category of import/export and cross-border logistics, the Merchant must ensure that their customers meet the above requirements. In addition, the Merchant must be able to demonstrate knowledge of trade-based money laundering and sanctions/proliferation risk and have adequate controls in place.

Precious metals and stones, arts and antiques, other valuable commodities, sale of vehicles or other merchants dealing with high value goods. If any payments are to be made to, or received from, a business providing these services the following restrictions also apply. These businesses must be located in countries with approvals to conduct business legitimately.

Weapons (i.e. knives and accessories for weapons intended for hunting, fishing and recreational activities; antique weapons or collectibles). If any payments are to be made to, or received from, a business providing these services the following restrictions also apply. These businesses must:

• Be evidenced to be for legitimate sport or recreational activities and not for military or dual use purposes.

UK and Ireland Limited Partnerships. This includes Limited Partnerships (LP), including Scottish Limited Partnerships (SLP) and Limited Liability Partnerships (LLP). These businesses must:

• Have all partners/ownership in the country of domicile.