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Prohibited Customers, Products & Services

  • Updated


Prohibited Customers

The following types of customers are prohibited by CoinJar, Inc. (“CoinJar”) and are subject to change:

  • Countries, governments, entities and individuals subject to sanctions or included in any applicable internal lists;
  • Customers engaged in the defense sector or the manufacture or production of arms, military equipment, or weapons of mass destruction (1). This includes, but is not limited to anti-personnel mines, chemical weapons, precursor chemicals, cluster munitions, military equipment or technology, nuclear weapons, military and dual-use equipment, internal repression equipment, or security and police equipment; 
    • There may be instances dependent on the Client Type or nature of business that may require an analysis of the customer’s activity/operations in the defense sector and annual revenue and percentage of sales/revenue attributed to the above referenced defense sector activities. These should be escalated to Financial Crimes Compliance.
  • Missions, embassies, and consulates;
  • New bearer share issuance or issued bearer shares that have not been immobilized or are not with an approved custodian;
  • Anonymous or numbered accounts or Customers seeking to maintain an account in an obviously fictitious name; 
  • Customers whose identities are not known or cannot be verified; 
  • Customers exited for financial crime concerns. In addition, customers or related parties where there is a strong suspicion or direct evidence that criminal activity has taken place, where a criminal offence has been committed and charges have been brought or where there is a suspicion of terrorist financing;
  • Shell banks (2);
  • Marijuana Related Businesses (MRBs);
  • Crypto Mining Industries;
  • Unlicensed or unregistered Money Services Businesses (MSBs) (3); 
  • Unlawful Internet Gaming Companies, their principals, and their payment processors and companies whose main source of revenue is derived from either the development of gambling software or hosting environments as defined in the Unlawful Internet Gambling Act of 2006 (UIGEA) and Prohibition of funding of Unlawful Internet Gambling (Regulation GG) (4);
  • Adult entertainment businesses, escort services and sexually oriented or pornographic products and services;
  • Payday lenders, their owners, and principals; and
  • Verified hackers

Prohibited Products and Services 

The following types of Products and services are prohibited: 

  • Payable-through accounts through domestic or foreign bank customers (i.e., correspondent accounts that are used directly by third parties to transact on their own behalf)Direct control of internal concentration or suspense accounts by customersThe physical transportation of currency and monetary instruments by employees (e.g., bulk cash on behalf of customers) 
  • Entities subject to Section 311 of the USA PATRIOT Act

 

  1. Inclusive of the production, trade and storing of weapons or critical components (e.g., those specifically designed for and which represent a critical component for the functioning of the weapon)
  2. A shell bank is an entity that has no physical existence in the country in which it is incorporated and licensed, and which is unaffiliated with a regulated financial group that is subject to effect consolidated supervision. See 31 CFR § 1020.313. or the provision of assistance, technology or services related to weapons or critical components.
  3. Unlicensed MSBs or companies offering services involving money/currency exchange, money transfer, cheque cashing, and issuing or selling travelers cheques, money orders or stored value cards that meet the regulatory definition.
  4. The Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA) prohibits gambling businesses from knowingly accepting payments in connection with the participation of another person in a bet or wager that involves the Use of the Internet and that is unlawful under any federal or state law (i.e., restricted transactions). Federal regulations require “participants in payment systems that could be used for unlawful Internet gambling to have policies and procedures reasonably designed to identify and block or otherwise prevent or prohibit the processing of restricted transactions.” (73 Federal Register 69382, November 18, 2008).


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