Prohibited Clients and Services

Bearer Share Entities and other Anonymous Ownership Entities

Any entity, including a trust, whose ownership control cannot be determined because the entity’s ownership certificates or shares are issued in bearer form.

Non-Licensed Money Services Businesses

Entities doing business, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities:

1. Currency dealer or exchanger
2. Check casher
3. Issuer of traveler's checks or money orders
4. Seller or redeemer of traveler's checks, money orders or stored value
5. Money transmitter

Criminal Offenders

Anyone prosecuted, convicted, or indicted for a serious crime specific to felonies and certain misdemeanors involving financial crimes, narcotics trafficking, terrorist financing, or moral turpitude determined to be outside the risk profile of the Bank.

Crowdfunding or Crowdsourcing Entities

Entities that facilitate the process of obtaining needed funds, services, ideas, or content by soliciting contributions from a large group of people rather than from traditional employees or suppliers.

Embassies, Consulates, and Diplomatic Missions

Official embassy, consular, or other diplomatic mission accounts, such as:

1. Diplomatic mission used as part of the operation of the mission, e.g. embassy, consulate, or international organization founded in international law or treaties with status of diplomatic mission
2. Personnel, e.g. Ordinary Ambassador, Extraordinary Ambassador, Consul, Consul-General, Chargé d’Affaires, First Secretary, Attaché, or other employee

Politically Exposed Person (PEP)

An individual who has been entrusted with a prominent public function. The Bank has made a business decision to not bank PEPs, business associates of PEPs, or immediate family members. In addition, the Bank will not open a relationship for a business owned or controlled by a PEP, immediate family member, or close associate.

Foreign Government Agencies

Any agency or judicial authority of a foreign government, including a foreign state, a political subdivision of a foreign state, or a multinational organization constituted by and comprised of foreign states, that is vested with law enforcement or investigative authority in civil, criminal, or administrative matters.

Informal Value Transfer System

Any informal value transfer system (also known as hawalas) acting as a form of money service business for fund transfers between parties.

Internet Gambling Entities

Any entity that engages in transactions in which a person accepts credit, funds, instruments, or other proceeds from another person in connection with any internet gambling. Accepting any form of payment either directly or indirectly from these entities is prohibited under Federal law. Accepting payment for legal gambling is also prohibited under SSB guidelines.

Internet Pharmacies

A pharmacy that operates over the Internet and sends orders to customers through mail, shipping companies, or online pharmacy web portals.

Marijuana Dispensaries, CBD, Kratom or related businesses

A facility where marijuana, marijuana products, or devices for the use of marijuana or marijuana products are offered for retail sale. Marijuana dispensaries are not considered legal under Federal law. Prohibited activities include any individual or business that operates, derives income from, leases to, collects rents, or otherwise obtains funds from an entity engaged in the direct or indirect sale of marijuana, CBD, and Kratom.

OFAC Specially Designated Nationals and Blocked Persons

Sanctioned countries, governments, entities, and individuals as designated by OFAC.

Shell Banks

Banks that do not maintain a physical presence in any country and that are not affiliated with a bank with a physical presence.

Shell Corporations

Any entity, including a trust, whose ownership cannot be determined because it is intentionally established to prevent the identification of beneficial ownership interests.

Title and Payday Lenders

An entity that lends customers small amounts of money at high interest rates, on the agreement that the loan will be repaid when the borrower receives their next paycheck.

US Sanctioned Countries

Below is a list of jurisdictions with comprehensive U.S. sanctions, meaning Reloadly is prohibited from conducting business with them without an OFAC license:

• Cuba
• North Korea
• Iran
• Syria
• Crimea region of Ukraine
• Afghanistan
• Belarus
• Russian Federation
• Sudan
• Venezuela