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PROHIBITED BUSINESS LIST


Last updated: November 2024

Prohibited Business Categories

At the outset, any business that meets any of the following conditions are not eligible to use Xflow's services:

  • are named as restricted persons or entities under any sanctions lists,
  • directly or indirectly provide goods or services to or otherwise engage or deal in, or are located in countries or regions which are under sanctions or are deemed high risk by Xflow,
  • offer products or services that are illegal or relate to any illegal activities under the laws of the jurisdictions in which such businesses are located or target to,
  • do not appear to have any legitimate purpose, including without limitation, activities such as money laundering, terrorist financing, human trafficking, fraud, wildlife trafficking, organ trafficking, environmental crime, political corruption, trafficking in endangered species etc.,
  • Entities involved in businesses that are prohibited by the applicable law or foreign trade policy of the originating/destination country, or the country where the relevant Xflow entity is based, or
  • Xflow deems it to be unfair, deceptive or predatory.

Without prejudice to the generality of the foregoing, the following categories of businesses are prohibited from using Xflow:

  1. Money or value transfer services (MVTS) - Examples of such businesses are money transmitters, check cashing, wire transfers, money orders, currency exchanges or dealers, bail bonds, collections agencies, remittance agents, or individuals running such business etc; informal value transfer systems, payment processing resellers/downstream processing providers etc;
  2. Entities with anonymous or fictitious names;
  3. Unregulated/unlicensed money service business (MSB) in jurisdictions which require license for such businesses; Unregulated/unlicensed banks; Unregulated/unlicensed financial institutions like, securities firms, broker-dealer, insurance companies, loan apps etc. in jurisdictions which require license for such businesses; Downstream/nesting to MSB or MVTS through an MSB Customer;
  4. Entities facilitating Payable through accounts (PTA) through domestic or foreign bank Customers, Cross-border bulk currency transfer or physical transportation of currency on behalf of Customer, International cash letter, Remote deposit capture, Virtual/digital currencies, Sponsoring private ATMs, Wholesale cross border banknotes/currency trading services, Buying, selling, and shipping large volumes of bank notes/currencies cross border, Receiving large shipment of currency on behalf of Customer or other banks, Only low price securities;
  5. Entities owning or having issued bearer shares except respondent / correspondent banking relationships wherein the capital structure has bearer shares historically;
  6. Entities involved in binary options, Cash advances, cash gifting, Check cashing, Credit repair services, Debt consolidation and Debt collection agencies, Foreclosure protection, Grant assistance, Mortgage modification/reduction, Payday lending, chit funds; Money mules;
  7. Shell companies or any other structures where the concerned entity is owned via nominal ownership or is managed via nominal directors, shell banks, bearer share companies, payable-through-account holders or any other businesses that appear to circumvent currency controls or anti-money laundering norms;
  8. Offshore holding/investment companies involved solely in managing or investing funds;
  9. Virtual currency or stored value or other virtual asset service providers - Virtual currency exchanges, miners, administrators, and any other virtual asset service providers; entities that directly service the crypto industry;
  10. Entities that are involved in or suspected of being involved in manufacturing, use, sale, or trade of counterfeit or pirated goods, sales, distribution, or access to counterfeit music, movies, software, or other proprietary materials without the appropriate authorization from the rights holder or other intellectual property or proprietary rights infringement including any product or service that directly or indirectly infringes or facilitates infringement of the trademark, patent, copyright, trade secrets, or other proprietary rights of any third party such as copyright unlocking technology;
  11. Entities engaged in the sale of goods or services that are illegally imported or exported;
  12. Entities engaged in the business of betting or gambling including lotteries, raffles, bidding fee auctions, sports forecasting or odds making, fantasy sports leagues with cash prizes, internet gaming contests, sweepstakes, games of chance, casinos and gambling equipment including "junket operators" that arrange gambling tours, bookmaking, racing (for cars and animals);
  13. Entities engaged in the business of online gaming activities (except those which are purely subscription based and do not offer rewards, prize money, winning or any other consideration in cash/kind to the player), fantasy games, betting;
  14. Entities in business of spas, friendship club, network marketing, multi-level marketing any other speculative activity;
  15. Entities engaged in the sale or distribution of Illegal products or services;
  16. Entities engaged in Medical benefits/discounts;
  17. Entities engaged in sale or distribution of Marijuana or recreational drugs or related products, marijuana dispensary, sale of tobacco and cigarettes, illicit drugs, psychoactive substance or paraphernalia, magical remedies alcohol or alcoholic beverages, e-cigarettes, and e-liquid, vape supplies, age-restricted goods or services;
  18. Entities engaged in the sale or distribution of toxic chemical agents, microorganisms;
  19. Entities engaged in the manufacture, sale, repair or distribution of weapons and munitions, firearms, dual-use goods, military equipment or technology, nuclear material, stealth materials, rocket fuel, propellant, systems, avionics, navigations systems, sensors, lasers, telecommunication equipment, gunpowder and other explosives, fireworks and related goods, provision of armed services, private security services, mercenary services;
  20. Entities or businesses which deal with toxic, hazardous, flammable, and radioactive materials, products and services with varying legal status on a regional basis, mining, oil drilling and refining;
  21. Entities involved in adult entertainment or prostitution, including sale or distribution of pornography and other obscene materials (including literature, imagery and other media; sites offering any sexually-related services such as prostitution, escorts, pay-per view, adult live chat or phone conversation features, businesses that primarily provide support/ services to the adult entertainment industry)\;
  22. Entities facilitating mail order brides; or
  23. Entities involved in timeshares, cruises

High Risk Business Categories

The following categories of businesses are deemed high risk. Onboarding will be permitted subject to additional due diligence checks being performed successfully:

  • Dealers of precious metals or stones or extractive industries
  • Charities or not-for-profits
  • Non government organizations (NGOs)
  • Crowdfunding platforms
  • Antiques and Auction houses
  • Collectible clubs
  • Discount buying clubs
  • Dating
  • Government organizations
  • Licensed financial institutions (including crypto)
  • Forex trading platforms
  • Licensed Money services businesses
  • Pawnbrokers
  • Motor vehicle dealers

Xflow reserves the right to deny services to the following categories of businesses and organizations, if Xflow determines, at its sole discretion, that such business or organization presents any anti-money laundering, terrorist financing, KYC or other compliance risks:

  • Shipping and general trading companies operating in free trade zones;
  • Tours and travel companies;
  • Electronic gaming platforms that facilitate the purchase of virtual gaming asset;
  • Payments involving motor vehicle dealers;
  • Online pharmacies, Tele-medicine or tele-health services;
  • Organizations set up for educational, cultural, social or political purposes;
  • Transactions involving penny stocks or microcap securities;
  • Transactions designed to achieve a particular tax treatment;
  • Transactions involving embassies, consulates and diplomatic missions;
  • Transactions involving economic citizenship or citizenship by investment programs; and/or
  • Transactions involving government scholarship programs where the beneficiary is not an educational institution.