Compliance and Financial Crime Risk Appetite Statement
Yapily maintains a zero tolerance for compliance and financial crime risk exposure, including all Money Laundering (ML) and Terrorist Financing (TF) Risk.
Yapily ensures that it adopts all regulatory, legal requirements and compliance requirements in a proportionate way that satisfies the requirements of the local regulatory authorities in a pragmatic and risk-based manner. Yapily is obliged to transact its business so as to ensure it minimises the risk of its systems and processes being used for ML or TF purposes.
Yapily has strict and transparent standards and continuously seeks to strengthen its processes to ensure compliance with all applicable laws and regulations. Yapily reserves the right to reject any client, payment, or business that is not consistent with its Risk Appetite.
Sanctions Compliance Statement
Yapily is committed to complying with the sanctions laws and regulations of the United Kingdom, European Union, the United Nations, Republic of Lithuania and the United States (the sanctions lists), as well as the applicable sanctions laws and regulations in the jurisdictions in which Yapily operates. This position is taken in order to manage regulatory, legal, operational and liquidity risks, and takes into account broader financial crime concerns.
Yapily’s internal policies prohibit or restrict dealing, directly or indirectly with parties subject to restrictive measures issued by these jurisdictions. Yapily reserves the right to refuse to engage in business involving parties with links to the sanctions lists, even where permitted by applicable sanctions laws and regulations where these activities fall outside of Yapily’s risk appetite. In some cases, this risk appetite may be stricter than our legal obligations.
PROHIBITED JURISDICTIONS
Yapily provides Account Information Services (AIS) and Payment Initiation Services (PIS) within the United Kingdom and European Union only. Yapily will not provide services to any entity or person located in the following jurisdictions:
| Jurisdictions |
|---|
| Myanmar |
| Iran |
| Russia |
| Korea, North |
| Crimea |
| Donetsk |
| Luhansk |
| Sevastopol |
| Syria |
| Cuba |
| Venezuela |
| Belarus |
RESTRICTED JURISDICTIONS
| Jurisdictions |
|---|
| Afghanistan |
| American Samoa |
| Anguilla |
| Antigua and Barbuda |
| Aruba |
| Azerbaijan |
| Azores |
| Bahamas |
| Bahrain |
| Bangladesh |
| Barbados |
| Belize |
| Bermuda |
| British Virgin Islands |
| Brunei |
| Bulgaria |
| Burkina Faso |
| Burundi |
| Cambodia |
| Cameroon |
| Cayman Islands |
| Central African Republic |
| Chad |
| China |
| Colombia |
| Comoros |
| Congo, Democratic Republic of the |
| Congo, Republic of the |
| Cook Islands |
| Croatia |
| Curaçao |
| Djibouti |
| Dominica |
| Ecuador |
| Equatorial Guinea |
| Eritrea |
| Fiji |
| Gibraltar |
| Guam |
| Guatemala |
| Guernsey |
| Guinea |
| Guinea-Bissau |
| Haiti |
| Honduras |
| India |
| Indonesia |
| Iraq |
| Isle of Man |
| Israel |
| Jamaica |
| Jersey |
| Kenya |
| Lebanon |
| Liberia |
| Libya |
| Madeira |
| Maldives |
| Mali |
| Marshall Islands |
| Mauritius |
| Mexico |
| Moldova |
| Monaco |
| Montserrat |
| Mozambique |
| Namibia |
| Nauru |
| Nicaragua |
| Niger |
| Nigeria |
| Niue |
| Pakistan |
| Palau |
| Panama |
| Paraguay |
| Philippines |
| Saint Helena, Ascension, and Tristan da Cunha |
| Saint Kitts and Nevis |
| Saint Pierre and Miquelon |
| Samoa |
| Senegal |
| Seychelles |
| Sint Maarten |
| Somalia |
| South Africa |
| South Sudan |
| Sudan |
| Syria |
| Tahiti |
| Tajikistan |
| Tanzania |
| Tonga |
| Trinidad and Tobago |
| Tunisia |
| Turkey |
| Turkmenistan |
| Turks and Caicos Islands |
| Uganda |
| United Arab Emirates |
| US Virgin Islands |
| Vanuatu |
| Vietnam |
| Yemen |
| Zimbabwe |
Prohibited Industries/activities
Yapily has defined a financial crime risk appetite that delineates the boundaries within which Yapily Connect operates. Below, we outline the prohibited industries, setting expectations for ourselves, our clients and their merchants.
“Prohibited” industries or clients denote those we do not engage with—neither our clients nor any of their merchants can fall within this list. This list is not exhaustive, and additional considerations may apply as per our ongoing risk assessments and compliance protocols.
PROHIBITED INDUSTRIES & ACTIVITIES
| Sector |
|---|
| Sanctioned entities or individuals (United Nations, United States of America OFAC, European Union, Republic of Lithuania and United Kingdom HMT sanctions lists) |
| Unregulated Virtual Asset Service Providers, Foreign Exchange Brokerage, Crowdfunding Platforms, CryptoATM and Payment Service Providers providers |
| Commercial activity which infringes on copyrighted material |
| Fake goods and counterfeit consumer products |
| Fortune-tellers |
| Unlicensed gambling establishments |
| Illegal goods, smuggled goods, or protected/cultural items & artefacts |
| Illegal pharmaceutical sales |
| Sales of substances designed to imitate recreational drugs (legal highs, research chemicals) |
| Unreasonably complex or opaque ownership structures |
| Shell companies |
| Armaments, nuclear, weapons, or defence manufacturers |
| Private military company, private military and security companies, private mercenaries |
| Weapons (knives, guns, etc.) dealers |
| Adult entertainment services sold or otherwise provided on an in-person basis, including date arrangement, escort services and any sexual services |
| Companies involved in Initial Coin Offerings (ICO) |
| Unauthorised nicotine-containing & alcohol-containing product sales |
| Religious organisations |
| Sale of live animals, including insects, animal parts or fluids |
| Mini-bond issuance |
RESTRICTED INDUSTRIES & ACTIVITIES
| Sector |
|---|
| Online Adult Content Providers |
| Crypto-asset service providers (e.g. exchanges, custodian wallet providers) |
| Foreign Exchange Brokerages/Dealers |
| Lotteries and gambling entities |
| Registered non-profit organisations, Charities |
| Travel agencies |
| Trade in Health Care products |
| Pharmaceutical businesses |
| Trade in licensed tobacco and alcohol products |
| Licensed trade in ferrous, non-ferrous and precious metals, stones and jewellery |
| Trade in art, cultural artefacts and other items of archaeological, historical, cultural and religious importance, or of rare scientific value |
| Companies selling timeshare |
| Electronic and surveillance equipment or software |
| Holding companies |
| Used car parts and used cars dealers |
| Pawnbrokers |
| Political organisations and institutions |
| Embassies, Diplomatic offices and Consulates |
| Special purpose vehicles (SPVs) and special purpose entities (SPEs) |
| Trusts |
| Sellers of THC-containing product/CBD-containing product/Cannabis seeds |
| In-game item & software key resellers |
| Payment Services Providers/Money Remittance Firms |
| Online gambling establishments (iGaming) |
| Payment Gateways/Facilitators |