Eligibility Criteria Statement

1. Accepted Business Activity

To apply for services from Clear Junction, you need to satisfy the below minimum eligibility criteria (Section 1) and not be involved in the prohibited business activities (Section 2). However, this is not a guarantee that we will be able to onboard you as a Client. The onboarding decision is made based on numerous factors, and the only eligibility according to this Eligibility Criteria Statement doesn’t mean that we will be able to open an account for you. Clients of Clear Junction must ensure that their underlying Customers also comply with the below requirements.

1.1. Legal Form: Clear Junction accepts only companies, and in certain circumstances, partnerships as Clients. We do not accept trusts, fund structures and foundations, contractual or hybrid entities, special purpose vehicles and similar arrangements.

1.2. Jurisdiction of Incorporation and Business Operations: The company must not be incorporated or conduct business in offshore countries (also known as “tax havens”) or the following jurisdictions, but not limited to:

 

1.3. Substance: Shell companies (a company with no physical presence involving effective decision-making, operations or assets other than cash or equivalents of cash, with no independent operations, ongoing business activities and/or employees) are not permitted.

1.4. Beneficial Transparency: Bearer share companies or companies utilising nominee directors, or shareholders, or similar arrangements to hide or obscure the true beneficial ownership are not permitted.

1.5. Licensing and Registration: If the company conducts financial or regulated activity (subject to AML regulations), it must possess the appropriate licenses, authorisations or registration statuses for the services in which it operates. The company should be at least registered for AML purposes with a local authority in the country of its incorporation, as well as, in the countries/territories where it conducts business activity.

1.6. AML/CFT/Fraud and Regulatory Compliance: If the company conducts financial or regulated activity (subject to AML regulations), it must have robust, up-to-date AML/CFT, Sanctions and Fraud Prevention (if relevant) policies and procedures that are relevant and proportionate to its business, effectively implemented KYC and transaction monitoring (if relevant) systems and controls, experienced MLRO/Compliance Officer, Compliance team and Onboarding team. It must be compliant with all international, local and exterritorial regulatory requirements applicable to their business (e.g. the UK Financial Promotion Regime).

1.7. Lawful Activity: The company must conduct lawful business, comply with the applicable laws, regulations, good industry practices, and must not engage in activity that is illegal, conducted in the absence of required licenses or permissions, that breaches any applicable local, national, or international law or regulation, infringes intellectual property or proprietary rights, promote hate, violence, discrimination, terrorism, harassment or abuse in any shape or form, facilitates tax evasion, or causes Clear Junction to breach any applicable law or regulation, in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect, or present an excessive reputational risk to Clear Junction.

1.8. Sanctions and Adverse Connections: The company, its directors, shareholders, beneficial owners, and affiliates must not appear on OFAC, OFSI, EU, or other relevant sanctions and watchlists in their jurisdiction of incorporation, residence, or business operation. Offering any products or services, directly or indirectly in or with sanctioned countries, entities, individuals, or crypto wallets are not permitted. Direct or indirect business relationships with, business operations in or financial flows to/from, entities or individuals connected to the Russian Federation, Belarus, Cuba, Iran, DPRK, Syria, specific regions and non-government controlled Ukrainian territories are prohibited.

1.9. Reputation: The company, its directors, shareholders, beneficial owners, and affiliates must maintain a positive reputation and avoid engagement in activities that could harm Clear Junction’s reputation, such as those involving financial crime, unethical practices, or significant negative media coverage.

2. Prohibited Business Activities

Clear Junction does not establish direct business relationships with and requires its Clients not to enter into business relationships with the entities or individuals related to the following industries and business activities. Clear Junction services also must not be used to initiate and/or receive payments with the following industries and business activities.

Please note that the below list is not exhaustive, Clear Junction may not accept other business activities as well, if we don’t think they are appropriate. In exceptional circumstances, Clear Junction may approve a company that does not fully satisfy the minimum eligibility criteria (Section 1) or is involved in the prohibited business activities (Section 2), undertaking a risk-based approach, depending on the facts and merits of the issue.

The prohibited business activities are as follows: 

2.1. We do not accept – Shell banks or regulated companies (banks or regulated companies 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).

2.2. We do not accept – Private banking (banks or regulated companies providing banking and investment services in a closely managed relationship to high net worth clients, including current account banking, high-value transactions, use of sophisticated products, non-standard investment solutions, business conducted across different jurisdictions and offshore and overseas companies, trusts or personal investment vehicles).

2.3. We do not accept – Financial institutions and regulated entities that will be using Clear Junction’s services for ‘nesting’, ‘layering’ or providing ‘payment through’ accounts.

2.4. We do not accept – Financial institutions and regulated entities that provide anonymous accounts, numbered accounts, or accounts in fictitious names.

2.5. We do not accept – Remittance businesses that primarily operate on a cash-funded basis (where the business is funded in cash or relies significantly on cash deposits for the initiation of remittance transactions).

2.6. We do not accept – Unlicensed or unregistered cryptoasset business, or licensed in offshore jurisdictions, or in jurisdictions where registration/licence is not required, or facilitating the exchange of anonymity-enhanced cryptocurrency, unlicensed facilitation of security tokens (e.g. tokens that have characteristics akin to traditional instruments like shares, debentures or units in a collective investment scheme), or operating cryptocurrency ATMs.

2.7. We do not accept – Unlicensed or unregulated high-risk financial businesses, including, without limitation, contract for difference (CFD), financial spread betting, initial coin/token offering (ICO) or similar, NFT, crypto mining and staking, forex and options, binary options, cryptocurrency derivatives, other financial instruments trading, financial advisors, get-rich-quick schemes, Ponzi, pyramid schemes, multi-level marketing (MLM), buy now pay later / instalment payment methods, loan repayment services, credit monitoring and repair services, hawala (and alternative informal value transfer system), and other high-risk financial businesses.

2.8. We do not accept – 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.

2.9. We do not accept – Crowdfunding, crowdlending and similar activities businesses.

2.10. We do not accept – Gambling, gaming and betting businesses.

In exceptional circumstances, Clear Junction / Client of Clear Junction may accept this business activity on a risk-based approach if the company satisfies the criteria covered in Section 1 and the below criteria:

  • 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 the United Kingdom.
  • Has a relevant financial licence in the country of incorporation / is registered with the local country gambling commission of the country of its incorporation.
  • Has a robust and up-to-date AML/CFT, Financial Sanctions and Fraud Prevention Policies and Procedures that are relevant and proportionate to its business, effective KYC and where relevant transaction monitoring tools, experienced MLRO, Compliance team and Onboarding team.
  • Established for more than three years.
  • 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 no material negative media which could result in material reputational damage for Clear Junction.

2.11. We do not accept – 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.

2.12. We do not accept – Unlicensed or unregulated holding/investment companies involved in managing or investing own- or third-party funds, proprietary trading companies, true holding companies with no business operations.

2.13. We do not accept – 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).

2.14. We do not accept – Adult Services.

2.15. We do not accept – 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.

2.16. We do not accept – Any business involved with Cannabidiol “CBD”.

2.17. We do not accept – 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.

2.18. We do not accept – 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.

2.19. We do not accept – Companies whose business activity is directly or indirectly related to alcohol businesses, tobacco, smoking supplies, e-cigarettes, e-liquids, vaping liquid, vaping accessories.

2.20. We do not accept – Wildlife Trafficking, including animals and wildlife products classified as endangered or protected.

2.21. We do not accept – Companies whose business activity is directly or indirectly related to atomic power, oil, gas and shipping companies, as well as related activities.

2.22. Corporate service providers (including offshore company formation, providing nominee directors and/or shareholders to obscure company ownership and opening accounts on behalf of other businesses, trust and other corporate service providers), legal (bankruptcy lawyers, bail bonds and law firms collecting funds for purposes other than legal service fee payment), debt relief companies (including debt settlement, debt negotiation, and debt consolidation) and accounting services.

2.23. 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.

2.24. Businesses that provide compensation to creators without an underlying piece of digital content associated. Examples include subscriptions to free, public content or a tip button on a profile page.

2.25. Businesses providing affiliate marketing schemes (including network marketing, referral marketing, multilevel marketing).

2.26. Other services that are out of the scope of Clear Junction’s scope of permissions and Clear Junction’s risk appetite.

3. Failure to Comply

3.1. Clients must comply with the requirements of this Eligibility Criteria Statement at all times.

3.2. Failure of a Customer to comply with or any breach of this Eligibility Criteria Statement will result in exercising its rights to delay or reject payments, suspend or terminate operations and business relationships, and if considered necessary, initiate legal action, report and disclose the information to law enforcement authorities.

3.3. Clear Junction may revise this Eligibility Criteria Statement at any time by amending this page without providing prior notice. We recommend checking this page regularly as it is legally binding to you.