Eligibility Criteria Statement
Eligibility Criteria
Introduction
Onboarding new clients is a critical part of any financial institution’s operations. It requires balancing your target client profile, identifying business opportunities, and aligning with the risk appetites of your banking partners, regulators, internal policies, and the jurisdictions in which you operate. This multi-layered process ultimately shapes your onboarding policy.
At Clear Junction, our approach is no different. When onboarding financial institutions, we take the time to fully understand each client’s business before granting access to our services.
To support a clear and transparent process, we have prepared a comprehensive though not exhaustive Eligibility Criteria Statement that outlines the key requirements for Clear Junction Clients and their Customers.
1. Accepted Business Activity
To apply for services from Clear Junction, clients 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 the client will be able to onboard.
The onboarding decision is made based on numerous factors, and the only eligibility
according to this Risk Appetite 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 (“tax havens”) or the following
jurisdictions, but not limited to:
● FATF: High-Risk Jurisdictions subject to a Call for Action (i.e. "black list")
● FATF: Jurisdictions under Increased Monitoring (i.e. "grey list")
● United Nations: United Nations Sanctions Regimes
● United States: Countries related to OFAC Sanctions Programs
● European Union: EU list of non-cooperative jurisdictions for tax purposes
● European Union: Countries which cooperate with the EU and have pending
commitments (‘State of play’ Annex II of Council conclusions on the revised EU list
of non-cooperative jurisdictions for tax purposes)
● Canada: Canadian Sanctions in Relation to Countries
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 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 licences, 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 provides products and services.
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 where relevant transaction
monitoring systems and controls, experienced MLRO/Compliance Officer, Compliance
team and Onboarding team. It must be compliant with all 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 licences 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 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
the Clients not to enter into business relationships with the entities or individuals
related to the following industries and business activities. Clear Junction services
must not be used to initiate and/or receive payments with the following industries and
business activities.
However, 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 crypto asset 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, 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 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. We do not accept – 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.
2.23. We do not accept – Corporate service provider 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.
2.24. We do not accept – 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.
2.25. 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 Risk Appetite Statement at all times.
3.2. Failure of a client to comply with or any breach of this Risk Appetite 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 Risk Appetite 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.
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 – FATF Jurisdictions under Increased Monitoring and High-Risk Jurisdictions subject to a Call for Action, EU and UK lists of High-Risk Third Countries.
• 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