Legal / Risk appetite policy

Risk appetite policy

MultiPass Platforms Limited expect our customers to value and show similarly high ethical principles, high standards of compliance and risk management. MultiPass Platforms Limited has strict policies regarding trading with PEP’s, sanctioned counterparties, criminals and persons involved with terrorism. In addition to the common practice of prohibiting payments linked to illegal activities, MultiPass Platforms Limited prohibits industries, payment linked to the following business activities:

  • Unregulated financial services (where licensing required)
    • Pyramid schemes / multi-level marketing (ML)
    • Hawala
    • Un-licensed FX broker
    • Binary options
    • Get rich quick schemes
    • Unlicensed gambling (e.g. provision of services using offshore licence)
  • Crypto-currency
    • Facilitating the exchange of anonymous crypto-currency
    • 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)
  • Unregulated pharmaceuticals / food supplements (e.g.“nutraceuticals”)
  • Piracy or illegal streaming
  • Counterfeit goods
  • Arms / dual-use goods
  • Unregistered Charities
  • Carbon Credits
  • Multi-Level Marketing
  • Pawnbrokers
  • Drug paraphernalia
  • Tobacco (Cigarettes, Cigars, Electronic cigarettes, Pipe tobacco, Snuff tobacco)
  • Alcoholic beverages
  • Unlicensed charities
  • Shell companies
  • Companies formed of Bearer Shares
  • Remittances funded in cash
  • Offshore and shell banks
  • Adult Entertainment
  • Firms involved in the servicing of illegal goods/services including but not limited to: Counterfeit Goods/trademark infringement, Human Trafficking, Child Labour, Prostitution
  • Fifth-party payments & multi-layered MSB arrangements
  • Financial Institutions making payments on behalf of other financial institutions, also known as ‘nested relationships’ or ‘Layering’
  • Political / religious organisations engaged in hate speech
  • Jurisdiction Jurisdictions listed by the IMF as Offshore Financial Centres and European Commission blacklist - Common EU list of third country jurisdictions for tax purposes

Failure to comply with these restrictions can result in delayed payments or rejected payments with continuous breaches leading to account closure.