Prohibited & Restricted Businesses¶

GIB prohibits certain activities and business types, and restricts others, to keep our clients and the bank safe. These controls are part of your Master Services Agreement (Exhibit B, "Bank Prohibited & Restricted Business List") and apply to every subclient, customer, payor, and payee you serve through GIB, and to every transaction you process on the platform.

You must not use GIB accounts or payment processing to provide services to any business that falls within the prohibited list below, and you must not process transactions in the prohibited merchant category codes (MCCs) listed here. Restricted businesses are not automatically barred, but they require GIB's prior written approval and additional due diligence before you onboard them.

Prohibited businesses¶

You may not serve, or process funds for, any business whose purpose is, or whose funds are derived from or intended for, the following:

• Countries, governments, entities, and individuals subject to sanctions or included in any applicable internal lists.
• Illegal drugs or drug paraphernalia (real or synthetic).
• Direct relationships to the cannabis industry, including cannabis (hemp and marijuana), cannabis growers, or products or services offered specifically for or intentionally toward the cannabis industry.
• Customers engaged in the defense sector or the manufacture or production of arms, military equipment, or weapons of mass destruction. This includes, but is not limited to, anti-personnel mines, chemical weapons, cluster munitions, military equipment or technology, nuclear weapons, military and dual-use equipment, internal repression equipment, and security and police equipment.
• Anonymous or numbered accounts, or customers seeking to maintain an account in an obviously fictitious name.
• New bearer share issuance, or issued bearer shares that have not been immobilized or are not held with an approved custodian.
• Customers whose identities are not known or cannot be verified.
• Customers terminated for financial crime concerns. This also covers customers or related parties where there is a strong suspicion or direct evidence that criminal activity has taken place, where a criminal offense has been committed and charges have been brought, or where there is suspicion of terrorist financing.
• Shell banks, meaning an entity that has no physical existence in the country in which it is incorporated and licensed and that is unaffiliated with a regulated financial group subject to effective consolidated supervision (Section 313 of the USA PATRIOT Act).
• Unlicensed or unregistered Money Services Businesses, meaning companies offering services involving money or currency exchange, money transfer, check cashing, or the issuing or selling of travelers checks, money orders, or stored value cards that meet the regulatory definition.
• Illegal activity, as directed by federal, state, or other international and local jurisdictions.
• Companies that have raised tokenized funding (for example, an initial coin offering or securitized token offering) that do not adhere to FinCEN and state money transmission laws or to SEC governance or the SEC Securities Act and Exchange Act requirements.
• Payment for debt that has been charged off as uncollectible.
• Psychics.
• Casas de cambio / currency exchange.
• Online dating.
• Pyramid and Ponzi investments.
• Technology developed to weaken industry security controls.
• Gambling.
• Crypto consulting companies, and unlicensed money or virtual currency transmitters, exchangers, and ATMs.
• Adult entertainment businesses, escort services, and sexually oriented or pornographic products and services.
• Payday lenders, their owners, and their principals.
• Diplomatic missions, embassies, and consulates.

Prohibited merchant category codes (MCCs)¶

In addition to the business types above, you must ensure that transactions in the following merchant category codes are blocked:

This list is not exhaustive. It also includes any other business or merchant category code prohibited from time to time by GIB, its affiliates, or a payment system.

Restricted businesses¶

The following activities and business types require GIB's approval prior to onboarding and are subject to additional due diligence. Do not onboard them without prior written approval:

• Gaming, including but not limited to sweepstakes, eSports tournaments, and transactions for in-game currency or goods.
• Websites or online services directed to children under 13 years of age, and operators of other websites or online services that have actual knowledge that they are collecting personal information online from a child under 13 years of age.
• Companies dealing in cryptocurrency, digital assets, digital currency, or currencies other than fiat currencies recognized by GIB.
• All other "financial institutions" defined under 31 U.S.C. § 5312(a)(2), with the exception of those described in paragraphs (K) and (R), notwithstanding the prohibited businesses listed above.