CUSTOMER ACCEPTANCE POLICY
Payment accounts and Cards
APRIL 2024
I. Scope
This Customer Acceptance Policy is a part of risk-based approach of Paynetics AD (hereunder Paynetics). The document is meant to outline the criteria for accepting new customers - natural persons or legal entities who use Paynetics`s payment services related to: - maintenance of payment accounts in BGN, EUR or GBP and execution of credit transfers to/from these accounts and - issuance of VISA or Mastercard payment cards and execution of card payments. Furthermore, it stipulates requirements about Paynetics’ Customers which shall be adhered to by Paynetics and its partners and representatives, especially by the employees who are involved in engagements with prospective customers. In line with regulatory updates and based on its risk appetite, Paynetics will review and update the Policy periodically.
II. General restrictions.
1. Customers are allowed to use Paynetics services for lawful purposes only.
2. Paynetics should inform its customers that they must comply with all applicable laws in all of their actions related to use of Paynetics’ services.
3. Paynetics should constantly monitor and control customers’ activity in order to prevent breaches of terms of this Policy.
4. Paynetics reserves the right to terminate a customer account at its own discretion, for example, when one of the aforementioned indicators is present and unresolved or where it has been established that maintaining the relationship with such customer would cause serious operational and/or reputational risk to the company.
III. Prohibited use
Paynetics prohibits usage of its services in following cases:
1. Customers listed in any Sanctions-related list of designated persons maintained by OFAC, the U.S. Department of State, the United Nations Security Council, the European Union, Her Majesty’s Treasury, or other relevant sanctions authority; or any person owned or controlled by any such person.
2. Customers, operating in one of the industries, classified as “prohibited” (see Appendix I)
3. Customers resided/established / incorporated in countries outside of the European Economic Area (EEA) and UK. By way of exception, Paynetics may accept a customer who is residing/established/ incorporated outside of the European Economic Area (EEA) and UK, provided that the country of residence/establishment of the customer is not present on the list with non-serviced/prohibited jurisdictions (see Appendix II).
APPENDIX I
The below list provides business models/ items that will not be considered for review by Paynetics. The list is not exhaustive and is intended to provide basic guidelines regarding the acceptance policy of the company. This list is updated from time to time and may also be extended at the sole discretion of Paynetics.
Paynetics do not solicit customer accounts falling into any one of below classified:
➢ Adoption agencies
➢ Adult related to Bestiality, Child pornography, Necrophilia, Incest, Rape, Violence, BDSM, banned content
➢ Antiques or art dealers
➢ Anti-Virus and registry cleaning software
➢ Any business which hosts and/or creates and/or helps distribute content and/or products which infringe on the intellectual property rights of others protected under copyright law. This includes businesses which sell fake, replica, or look-alike goods
➢ Any business which sells and/or organizes the sale of items covered under the UNESCO 1970 Convention
➢ Any customer that does not meet Paynetics policy guidelines
➢ Any customer that is currently in business bankruptcy or has been the subject of bankruptcy or receivership proceeding in the last 3 years
➢ Any customer that represents unacceptable reputation risk to Paynetics
➢ Blockchain-driven fund-raising (ICOs)/Unlicensed Cryptocurrency businesses
➢ Business/investment opportunities (“get rich quick schemes”, including internet search/ad optimization)
➢ Businesses promoted hatred, racism, or religious persecution
➢ Chemical Materials
➢ Escort and Escort Advertisements/Online Ad Boards services, Prostitution, sex solicitation, Replicas of famous persons or cartoons (without copyrights), Adult content which depicts religion, User-generated adult content
➢ File sharing/File storage/Cyber Locker/Cloud services and other P2P software’s
➢ Foreclosure Protection/Guarantees
➢ Citizen applications
➢ HD DVD and Blue Ray – Disk Decryption Devices
➢ Illegal sale of tobacco products and alcohol;
➢ Illegal/unlicensed pharmacies, prescription drug stores or prescription drug discounts
➢ Inbound/Outbound Telemarketing Merchants (MCC 5966) - Companies that solicit orders primarily with outbound telephone calls, facsimile or email. Includes “Up-Sellers.”
➢ In-game virtual items/ CS:GO Skins
➢ Lifetime Subscriptions (any product or service)
➢ Lottery Syndicates
➢ Marijuana industry, Psilocybin Mushrooms etc or other recreational drug industries;
➢ Merchants engaged in any form of deceptive marketing practices including but not limited to: Cross-sales; Hidden Disclosures; Bogus Claims & Endorsements; Pre-checked Opt-In Boxes; Refund/Cancellation, Avoidance; Up-sale
➢ Merchants engaged in any kind of Activity Prohibited by the Card Brands
➢ Merchants engaged in offering of Mystery Boxes
➢ Multilevel marketing schemes that do not involve a “real” (of independent value) product or service (like Pyramid or Ponzi Schemes) and the primary objective is solicitation of new distributors
➢ NFTs – any type of non-fungible tokens
➢ Offshore forex merchants/CFD/Binary options
➢ Offshore gambling merchants
➢ Payday loans
➢ PC support call centers, Registry cleaners and Bug fixes
➢ Piracy or illegal streaming
➢ Remittances funded in cash
➢ Replica – merchants selling fake products designed to look like the designer name products
➢ Sales-incentive-based programs that rely on “breakage” to earn profit. “Breakage” is defined as services paid for by the cardholder but never used. Prepaid and gift card program models are not considered breakage and are not, per said, unacceptable
➢ Shell and offshore banks
➢ Shell companies
➢ Substances Designed to Mimic Illegal Drugs (including herbal smoking blends & herbal incense)
➢ Third party billing companies
➢ Timeshares and timeshare advertising
➢ Trade of precious metals and gems
➢ Travel-Outbound Telemarketing (MCC 5962) - including discount travel clubs, membership or subscriptions to travel services or newsletters where subscribers may select prepackaged trips
➢ Unlicensed/ Unregulated CFD/FX brokers / Binary options
➢ Unlicensed/ Unregulated financial institutions / money service businesses / foreign exchange businesses
➢ Unlicensed/ Unregulated gambling merchants
➢ Unlicensed Charities
➢ Unregulated Crowdfunding
➢ Weapons, firearms, munitions of any sort
➢ Websites promoted hatred, racism, or religious persecution
➢ Win a car, boat or a real estate’ competition
APPENDIX II
NON-SERVICED / PROHIBITED JURIDSICTIONS
Paynetics evaluates geographical risks on products and services and maintains a register of prohibited countries / jurisdictions:
Paynetics does not maintain business relationships with individuals, who are residing or nationals, or legal persons, who are established or incorporated in any of the prohibited countries / jurisdictions:
➢ Afghanistan
➢ Albania
➢ American Samoa
➢ Anguilla
➢ Antigua and Barbuda
➢ Bahamas 4
➢ Barbados
➢ Belarus
➢ Belize
➢ British Virgin Islands
➢ Brunei Darussalam
➢ Burkina Faso
➢ Cambodia
➢ Cameroon
➢ Cayman islands
➢ Central African Republic
➢ Christmas Island
➢ Cook Islands (The Cook Islands)
➢ Congo (Democratic Republic of)
➢ Costa Rica
➢ Cuba
➢ Curacao
➢ Democratic People’s Republic of Korea (North Korea);
➢ Ethiopia
➢ Fiji
➢ Grenada
➢ Guam
➢ Guernsey
➢ Guyana
➢ Dominica
➢ Dominican Republic
➢ Haiti
➢ Hong Kong
➢ Iran
➢ Iraq
➢ Jamaica
➢ Jordan
➢ Kenya
➢ Labuan
➢ Lebanon
➢ Liberia
➢ Libya
➢ Macao
➢ Malaysia
➢ Maldives
➢ Mali
➢ Marshal Islands
➢ Mauritius
➢ Montseratt
➢ Morocco
➢ Mozambique
➢ Myanmar (Burma)
➢ Nambia
➢ New Caledonia
➢ Nicaragua 5
➢ Nigeria
➢ Oman
➢ Pakistan
➢ Palau
➢ Panama
➢ Philippines
➢ Pitcarin (the Pitcairn Islands)
➢ Russian Federation
➢ Saint Kitts and Nevis
➢ Saint Lucia
➢ Saint Vincent and Grenadines
➢ Samoa
➢ Sark
➢ Senegal
➢ Seychelles
➢ Singapore
➢ Somalia
➢ South Africa
➢ South Sudan
➢ Sudan
➢ Syria
➢ Tanzania
➢ Trinidad and Tobago
➢ Turkey
➢ Turks and Caicos Islands
➢ Uganda
➢ United Arab Emirates
➢ Ukraine’s non-government-controlled territories of Crimea, Sevastopol, Donetsk, Kherson, Luhansk and Zaporizhzhia regions.
➢ US Virgin Islands
➢ Vanuatu
➢ Venezuela
➢ Vietnam
➢ Yemen
➢ Zimbabwe
* Under an explicit decision of the Risk Committee and when it is permitted by the applicable law, Paynetics may enter into business relationships with a customer who is residing/established in a country listed above in this APPENDIX II