vIBANs Eligibility Criteria

Clear Junction Risk Appetite[1]

Once a Client opens the master account for their collection/payout needs, they can allocate unique virtual accounts for their Customers. Clear Junction as a regulated financial institution operates within a specific risk appetite which means some  businesses may not be supported or face certain restrictions. While Clear Junction may revise this Risk Appetite Statement at any point in time, please review restrictions below to minimise Customer onboarding challenges and streamline the virtual account generation process for your Customers.

1. The prohibited business activities for Client’s Customers are as follows:

1.1 We do not accept Client’s Customers that operate as Financial Institutions.

1.2 We do not accept Client’s Customers that operate as Crypto Exchanges.

1.3 We do not accept Client’s Customers that operate as unlicensed or unregulated high-risk financial businesses,including, without limitation, contract for difference (CFD), financial spread betting, initial coin/token offering (ICO) or similar, forex and options, binary options, cryptocurrency derivatives, other financial instruments trading, financial advisors, get-rich-quick schemes, Ponsi, pyramid schemes, multi-level marketing (MLM), hawala (and alternative informal value transfer system), and similar high-risk financial businesses.

1.4 We do not accept Customers whose primary business model involves the generation, aggregation, or sale of consumer leads.

1.5 We do not accept Client’s Customers that operate as 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.

1.6 We do not accept Client’s Customers that operate as crowdfunding, crowdlending and similar activities businesses.

1.7 We do not accept Client’s Customers that operate as gambling, gaming and betting businesses. In exceptional circumstances, Clear Junction may accept this business activity on a risk-based approach if Client’s Customer satisfies pre-defined criteria (country of incorporation, type of license, robust AML practices, no material negative media, years in operation).

1.8 We do not accept Client’s Customers that operate as charities, social service organisations, non-government organisations (NGOs) and other non-profit organisations, as well as political organisations, governmental services, such as embassies or consulates.

1.9 We do not accept Client’s Customers that operate as companies whose business activity is directly or indirectly related to weapons of war, automatic weapons, ammunitions or defence equipment, including but not limited to chemical weapons, cluster bombs, ammunitions, explosive devices and firearm parts, or other defence equipment or similar military weapons or that might be used for dual use purposes (except weapons for legitimate sport or recreational activities).

1.10 We do not accept Client’s Customers that operate as Adult Services.

1.11 We do not accept Client’s Customers that operate as companies whose business activity is directly or indirectly related to illegal/unlicensed/unregulated drugs, illegal sale of prescription drugs, intravenous therapy (e.g IV drip bar, vitamin infusions, hang over cures), tools specifically intended for the production of drugs, drug paraphernalia, synthetic stimulants, smart drugs, nootropic supplements, anabolic steroids and peptides, substances designed to mimic illegal drugs, other psychoactive products and substances, or other products that present a risk to

consumer safety.

1.12 We do not accept Client’s Customers that operate as any business involved with Cannabidiol “CBD”.

1.13 We do not accept Client’s Customers that operate as companies whose business activity is directly or indirectly related to hazardous materials, including but not limited to hydrofluoric acid, products containing cyanide, prohibited ozone-depleting substances (ODS), nitric acid, research chemicals, bacteria cultures or other products containing e-coli or escherichia coli.

1.14 We do not accept  Client’s Customers that operate as companies whose business activity is directly or indirectly related to counterfeit products, replicas or designed infringements of them including products designed to circumvent IP, essay mills, paper mills where the intent is to falsely submit documents as their own work, products designed to circumvent copyright protection techniques or to otherwise facilitate the unlicensed use of copyrighted material, fake

references and other services or products that foster deception.

1.15 We do not accept Client’s Customers that operate as companies whose business activity is directly or indirectly related to alcohol businesses, tobacco, smoking supplies, e-cigarettes, e-liquids, vaping liquid, vaping accessories.

1.16 We do not accept Client’s Customers that operate Wildlife Trafficking, including animals and wildlife products classified as endangered or protected.

1.17 We do not accept Client’s Customers that operate as companies whose business activity is directly or indirectly related to atomic power, oil, gas and shipping companies, as well as related activities.

1.18 We do not accept Client’s Customers that operate as companies whose business activity is directly or indirectly related to Cultural artefacts, ivory or other items related to protected species, or other items of archaeological, historical, cultural or religious significance or of rare scientific value.

1.19 We do not accept Client’s Customers that operate as corporate service providers and other legal and accounting services. Trust and corporate service providers that are involved in:

● Opening accounts on behalf of other businesses.

● Offshore company formation.

● Using nominee directors and/or shareholders to obscure company ownership.

1.20 We do not accept Client’s Customers that operate as cash-intensive businesses, high-value dealers, art dealers and galleries, auction houses, precious metals and stones, antiques, other valuable commodities, and other merchants dealing with high-value goods.

1.21 The list above is not exhaustive, The list above is not exhaustive, Clear Junction reserves the right to decline other business activities that are deemed inappropriate or pose an unacceptable level of risk to our operations.

2. Geographical Risk

The following jurisdictions are Prohibited countries for accounts with Clear Junction.

This list changes according to changes prescribed by various internationally accepted jurisdiction risk guides. Primarily these are – offshore countries (“tax havens”), FATF High-Risk Jurisdictions subject to a Call for Action, EU and UK lists of High-Risk Third Countries subject to financial sanctions.

• Afghanistan

• American Samoa

• Anguilla

• Antigua and Barbuda

• Aruba

• Bahamas

• Barbados

• Belarus

• Belize

• Bermuda

• Bosnia and Herzegovina

• Cayman Islands

• Central African Republic

• Congo, Democratic Republic of the

• Cook Islands

• Costa Rica

• Cuba

• Curaçao

• Dominica

• Dominican Republic

• Fiji

• Guam

• Guinea

• Guinea-Bissau

• Haiti

• Iran (Islamic Republic of)

• Iraq

• North Korea (Democratic People’s Republic of Korea)

• Lebanon

• Libya

• Mali

• Marshall Islands

• Mauritius

• Myanmar (Burma)

• Nicaragua

• Niger

• Palau

• Palestine, State of

• Panama

• Puerto Rico

• Russian Federation

• Saint Kitts and Nevis

• Saint Lucia

• Saint Vincent and the Grenadines

• Samoa

• Seychelles

• Somalia

• South Sudan

• Sudan

• Syrian Arab Republic

• Trinidad and Tobago

• Turks and Caicos Islands

• Vanuatu

• Venezuela (Bolivarian Republic of)

• Virgin Islands (British)

• Virgin Islands (U.S.)

• Yemen

• Zimbabwe

[1] Applies to EMIs, MSBs, Banks (and other types of PSPs) generating vIBANs for their Customers.