NON-ACCEPTABLE USE (PROHIBITION
Yapily Connect has zero risk appetite for supporting financial crime or other illegal acts, or for infringing international sanctions regimes. Therefore the use of Yapily Connect services to support clients that fall into any of the following categories are prohibited:
- Sanctioned entities or individuals¹
- Companies involved in illegal activity²
- Companies registered in Iran or Democratic People’s Republic of Korea DPRK or having significant links to these jurisdictions
- Unregulated crypto exchanges and/or custodian wallet providers
- Unregulated forex brokerages
- Unregulated lotteries and/or gambling operators and their payment agents, distributors
- Uses cases which are frequently associated with tax evasion³
- Arms and defence trade businesses registered outside NATO countries
- Companies pending incorporation or legal registration
- Companies with shares in bearer form
- Shell companies (incl. banks)
HIGHER RISK BUSINESS RELATIONSHIPS
Some high risk sectors and client types require a higher level of due diligence and/or ongoing supervision. The following is a non-exhaustive list of businesses or use cases which are deemed high risk from a AML/CTF risk perspective and require individual consideration:
- Adult content services⁴
- Crypto exchanges and/or custodian wallet providers
- Forex brokerages
- Lotteries and gambling operators and their payment agents
- Trust and other complex structures
- Entities that act as a personal assets holding vehicle
- Entities with nominee shareholding structures
- Non-profit organisations
- Charities
- Arms and defence trade businesses registered in NATO countries
- Cash intensive businesses
- Travel agencies
- Health Care
- Pharmaceutical businesses
- Trade in oil products
- Trade in tobacco and alcohol products
- Mining and extraction
- Trade in real estate
- Activities related to ferrous, non-ferrous and precious metals, stones and jewellery
- Activities related to art, cultural artefacts and other items of archeological, historical, cultural and religious importance, or of rare scientific value, ivory and protected species.
References
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According to the United Nations, United States of America OFAC, European Union and United Kingdom HMT sanctions lists.
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E.g., sale of illegal drugs, counterfeit products, entities carrying out regulated activities without appropriate licences or permissions.
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E.g. businesses registered or transacting with tax havens and other jurisdictions with favourable tax regimes that can be misused for illegitimate tax planning purposes or purposes or those that have unreasonably complex, opaque ownership structures.
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E.g. pornography, businesses offering any sexually-related, age restricted services such as prostitution, escorts, pay-per view, adult live chat feature.
Prohibited Entities
Last updated 20/9/2023
The following represents a non-exhaustive list of entities that Yapily understands have been deemed prohibited by regulators and no services utilising Yapily Connect Limited or Yapily Connect UAB may be provided to any such entity.
Customers remain responsible for ensuring that Yapily Services are provided in accordance with the terms of any agreement between us and in accordance with applicable law.
UK
FCA: Warning list of unauthorised firms
Gambling Commission: Any entity that has had its licence(s) suspended, revoked or terminated. A list of enforcement actions taken by the Gambling Commission can be found here.
Lithuania
Bank of Lithuania:
- The list of entities without the right to provide financial (including investment) services in Lithuania: https://www.lb.lt/en/the-list-of-entities-without-the-right-to-provide-financial-including-investment-services-in-lithuania
Gaming Control Authority under the Ministry of Finance of the Republic of Lithuania
- List of illegal gambling operators: https://lpt.lrv.lt/en/illegal-online-gambling-operators
Germany
Gemeinsame Glücksspielbehörde der Länder (GGL):
GGL have notified us that the following named entities are specifically prohibited from providing gambling-related activities in the following territories:
| Jurisdiction | Entity |
|---|---|
| Germany | L.C.S Limited |
The GGL operates a “whitelist” at https://www.gluecksspiel-behoerde.de/de/erlaubnisfaehigesgluecksspiel/whitelist.
If a gambling provider is not on the whitelist, they are not permitted to provide gambling-related services in Germany. The listed entities are therefore a small subset of those that are prohibited from providing these services in Germany.
- bo-nusbet .com
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