Terms and Conditions

Terms & Conditions

Last updated: March 13 , 2023

Pay by Bank transactions are provided by Firepay Merchant Services, a simplified Stock Company, registered at RCS Paris, under number 901543991, with registered address at 25, Rue de Ponthieu, 75008 Paris. VAT number FR94901543991.

Pay by Crypto services are provided by Qori Merchant Services SAS, a simplified Stock Company, registered in RCS Paris under number 912 740 271 RCS Paris, with registered address at 25, Rue de Ponthieu – 75008 Paris – France and VAT number FR65912740271.

We are working with partners to deliver our leading solutions. Their T&Cs also apply to the transactions you are performing. Please click below to access these T&Cs:

Yapily               Payment Initiation Service Provider          

Coingate         Crypto Exchange     

Bridge              Payment Initiation Service Provider

Terms & Conditions

The Pay by Bank transactions are provided by Firepay Merchant Services, a subsidiary of SYLQ. This page (our “Terms of use”) and the documents referred to in it, together with our Privacy Policy and the documents referred to in them (the “agreement”), constitutes the Terms of use on which you use our Services (as defined below) where:

  • you have contracted with us directly to open an account as a guest or a registered user, in which circumstances you shall be a “Direct User”; or
  • you have entered into a contract with a service provider which has made our services available to you (a “Distributor”), in which circumstances you shall be a “Referred User”.

At all times when you are using our Services, the contract for use of our Services is between you and us, whether you are a Direct User or a Referred User.

Please read this agreement carefully before you start to use our Services. By using our Services, you indicate that you accept this agreement and that you agree to abide by its terms. If you are using our Services on behalf of your organisation, by using our Services you are also indicating that you accept this agreement and agree to abide by its terms on behalf of your organisation (and references to “you” will be deemed to include your organisation).

To use our Services you must be at least 18 years old.

To the extent we are providing Services in relation to bank accounts in Europe the terms “payment account”, “payment services”, and “payment service provider” have the meanings given to them in the Second Payment Services Directive (the “PSD2”). To the extent we are providing Services in relation to bank accounts in the EU, the terms described in this paragraph will have the meaning given in the PSD2 and, where applicable, subject to the relevant member state’s local law implementation of the PSD2. To the extent we are providing Services in relation to bank accounts outside the EU, the terms will have the meaning given in any equivalent local law and regulation. The term “agreement” means these Terms of use, the documents referred to in it, and our Privacy Policy and the documents referred to in them, once accepted by you.

References in these Terms of use to our “app” apply only to Direct Users who have opened an account directly with us for use of our app.

  1. Disclaimer

All information, content and material displayed through our Services are provided for information only. It is not financial or professional advice. You should not rely on information, content or materials through our Services as the sole basis for making a financial decision. You should use your own judgement      and seek professional advice if appropriate. Accordingly, you agree that we are not responsible or liable to you for:

  1. any action (or inaction) resulting from use of or reliance on information, content and materials displayed through our Services (or any loss or damage you suffer as a result);
  2. third party sites or services linked to or accessed through our Services (or your use of, or reliance on, those sites or services); or
  3. any dealings you have with third parties not under our control (including your payment service providers) through our Services.

You acknowledge that alerts may be delayed or prevented by a variety of factors and we cannot guarantee that they will be delivered on time or based on accurate information.

  1. Payment Account providers

We are responsible for retrieving and transmitting your Transaction Data safely and securely but not for the content of your Transaction Data itself, which is the responsibility of your payment service provider. If you have any questions in relation to this, you should speak to your payment service provider.

  1. Access and registration

Access to our Services may be suspended temporarily and without notice in the case of system failure, emergency maintenance emergency upgrades or emergency repairs.

The information you provide when signing up to use our Services must be true, accurate, current and complete. You are responsible for maintaining your Registration Data to ensure that it remains accurate and up to date.

If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures by us, you must treat such information as confidential, and you must not disclose it to any third party.

You are responsible for making all arrangements necessary for you to have access to our Services. You are also responsible for ensuring that all persons who access our Services through your Internet connection are aware of this agreement, and that they comply with its terms.

  1. Our Services change regularly

We aim to update our Services regularly, and may change the content at any time. If the need arises, we may suspend access to our Services, or withdraw them indefinitely. Any of the material provided via our Services may be out of date at any given time, and we are under no obligation to update such material.

  1. Reliance on information posted

Commentary and other materials posted on our Services are not intended to amount to advice on which reliance should be placed. We therefore disclaim all liability and responsibility arising from any reliance placed on such materials by any person using our Services, or by anyone who may be informed of any of its contents.

  1. Our intellectual property and your licence to use our Services

Except as set out in these Terms of use, we are the owner or the licensee of all intellectual property rights (including but not limited to copyright, trademarks, patents, service marks, trade names, rights in know-how, database rights, design rights and other intellectual property rights or equivalent forms of protection, of whatever nature arising anywhere in the world, whether registered or unregistered and including applications for the grant of such rights (together, “Intellectual Property Rights”) in and to:

  1. our app and our Services;
  2. any necessary software used in connection with our Services (which, where you are a Direct User, include our app) (the “Software”); and
  3. all content contained within or generated by our Services (which, where you are a Direct User, include our app), including but not limited to text, images, charts, graphs and other materials, and specifically including charts, graphs, spreadsheets and other content generated from your Contributions (as defined below) (together, “Content”).

Except for the limited licence  granted to you under these Terms of use, we and our licensors expressly reserve all Intellectual Property Rights in and to our app, our Services, the Software and the Content.

Subject to your compliance with these Terms of use, we grant you a personal, limited, non-transferable, non-sublicensable, revocable, worldwide and non-exclusive licence to use our app, our Services, the Software and the Content for your own internal business purposes (if you are a business user) or your personal use (if you are a consumer) in accordance with these Terms of use and any other written or other instructions we may give you from time to time (including any instructions or parameters set down by us within or as part of our Services).

Your licence to use the Software is restricted to use of the object code of the Software, and it is a condition of such licence that, except to the extent expressly permitted under applicable law, you do not (and do not allow any third party to) copy, modify, create a derivative work from, reverse engineer, reverse assemble or otherwise attempt to discover any source code, sell, assign, sublicense, grant a security interest in or otherwise transfer any right in the Software. Additionally, you understand that you may have to agree to additional terms and conditions before you use such Software or any Content proprietary to a third party.

Without prejudice to rest of this clause, you agree:

  1. not to access our Services by any means other than through the interfaces that we provide for use in accessing the Service; or
  2. except as expressly authorised by us or relevant third parties, not to modify, rent, lease, loan, sell, distribute or create derivative works based on our Services (including, where you are a Direct User, our app), the Software or the Content, in whole or in part.

You may print off one copy, and may download extracts, of any Content from our Services for your personal reference and (if you are a business user) you may draw the attention of others within your organisation to Content posted via our Services.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text. Our status (and that of any identified contributors) as the authors of material provided via our Services must always be acknowledged.

Breach of this clause 8 will be deemed to be a material breach of these Terms of use. If we determine (in our sole discretion) that you have committed such a breach, your licence      under this clause 8 will immediately terminate and you must, at our option, return or destroy all copies of the Content you have made.

  1. Your uploads and confidential information

You retain (and we claim no ownership of) all intellectual property rights in and to any information, data, commentary or other materials (“Contributions”) which you upload to our Services and any Transaction Data.

However, by using our Services, you grant us a worldwide, non-exclusive, royalty-free, perpetual, sublicensable and transferable licence to use, copy, store, transmit, reproduce, process, modify, publish and prepare derivative works of your Contributions and Transaction Data for the purposes of providing you (and your organisation, if applicable) with our Services and for our product development, research and testing purposes.

Any Contributions which are expressly marked (or provided a similar designation) to be considered confidential or could reasonably be expected to be regarded as confidential to you will be treated as confidential and secret and will only be used and disclosed in accordance with these Terms of use, our   and/or to the extent we are required by applicable law to disclose any Contributions. We shall only disclose such information in the event that such information:

  1. is or becomes public (other than through breach of these Terms of use by us);
  2. was lawfully known by us before receiving it from you;
  3. is received by us from a third party without knowledge of breach of any obligation owed to you;
  4. is expressly authorised by you to be shared with, or disclosed to, third parties; or
  5. was independently developed by us without reference to your information.

You also agree and understand that your Contributions (and our Content based on your Contributions) will be visible by any third party with whom you have shared such information.

You acknowledge that, when using our Services, you may receive or have access to material which is expressly marked (or provided with a similar designation) to be considered confidential or could reasonably be expected to be regarded as confidential. You will keep such information strictly confidential for an indefinite period and not disclose such information unless:

  1. any use or disclosure of such information is expressly authorised in writing by us or required by applicable law; or
  2. such information is already in, or comes into, the public domain otherwise than through your unauthorised disclosure.

Whenever you make use of a feature that allows you to upload material to our Services, or to make contact with other users of our Services, you must comply with the content standards set out below. You warrant that any such contribution does comply with those standards, and you agree to fully reimburse and compensate us on demand for any breach of that warranty in accordance with clause 14 below.

  1. Additional services

Additional terms and conditions may apply to some of our specific Services. Where this is the case, you will always be given the opportunity to review and accept the terms before using the Service in question.

  1. Content standards

These content standards apply to any and all Contributions and to any interactive services associated with it.

You must comply with the spirit of the following standards as well as the letter. The standards apply to each part of any Contribution as well as to its whole.

Contributions must:

  • Be accurate (where they state facts).
  • Be genuinely held (where they state opinions).
  • Comply with applicable law in France and in any country from which they are posted.

Contributions must not:

  • Contain any material which is defamatory of any person.
  • Contain any material which is obscene, offensive, hateful or inflammatory.
  • Promote sexually explicit material.
  • Promote violence.
  • Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.
  • Infringe any Intellectual Property Right of any other person.
  • Be likely to deceive any person.
  • Be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence.
  • Promote any illegal activity.
  • Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety.
  • Be likely to harass, upset, embarrass, alarm or annoy any other person.
  • Be used to impersonate any person, or to misrepresent your identity or affiliation with any person.
  • Give the impression that they emanate from us, if this is not the case.
  • Advocate, promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.

We will not be responsible, or liable to any third party, for the content or accuracy of your Contributions, and we have the right to remove any Contribution you make on our Services if, in our opinion, such Contribution does not comply with the content standards set out in this clause.

If you wish to make a complaint in relation to any Contributions posted on our Services, or if you believe that any Contribution posted on our Services infringes an Intellectual Property Right that you own or have rights to, please contact us immediately at support@sylq.io.

  1. Deleting accounts

Please let us know if you would like to delete your account. Please note that deleting your account will cause all of the personalised elements of our Services (including your Contributions and the Content derived from your Contributions) to be irretrievably deleted and we will not be liable for the loss of any such data. Personal data associated with your account will be treated in accordance with our Privacy Policy.

  1. Our liability

Whilst we take every reasonable precaution and care in relation to our app and our Services, the material displayed on our app and our Services are provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we expressly exclude all conditions, warranties and other terms     .

We do not limit our liability for:

  1. death or personal injury arising from our negligence;
  2. fraud or fraudulent misrepresentation; or
  3. any other liability which cannot be excluded or limited under applicable law.

Subject to the above:

If you are a client     :

  • If we fail to comply with these terms, we are not responsible for any loss or damage you suffer which was not caused by our breach of these Terms of use or which was not foreseeable at the time you accepted these Terms of use.
  • If you are a Direct User using our app and our app is defective (for example if the app damages your device or other digital content owned by you) and this is caused by our failure to use reasonable care and skill, we will either repair the damage or pay you compensation. However, we will not be liable for damage that you could have avoided by following our advice to install the latest software update offered to you free of charge or for damage that was caused by you using the app in a manner that we do not authorise, or for you failing have in place reasonable anti-virus software or the minimum system requirements required to use the app.

If you are a business user:

  • We accept no liability under or in connection with this agreement (whether such liability arises in contract, tort (including negligence) or otherwise) for any:
  1. loss of income or revenue;
  2. loss of business;
  3. loss of profits or contracts;
  4. loss of anticipated savings;
  5. loss of data;
  6. waste of management or office time;
  7. (for each of (i) – (v) above, whether directly or directly occurring); or
  8. for any indirect or consequential loss or damage of any kind however arising.
  • Subject to the above, to the extent permitted by applicable law, our total aggregate liability to you for all and any damages, losses or causes of action arising, by reason of or in connection with your use of (or inability to use) our Services, shall be limited to any fees paid by you to use our Services or our Services in the twelve (12) month period immediately prior to the date on which you made the claim.
  1. Compensation

You agree to fully reimburse and compensate us on demand and hold us and our subsidiaries and affiliates, and our and their officers, directors, agents, co-branders or other partners, and employees, harmless from any losses, damages, costs, expenses (including reasonable legal fees), sums agreed to in settlement and other liabilities, arising out of any claim, demand, allegation or proceeding brought by any third party due to or arising out of:

  • any fraud or fraudulent misrepresentation you commit;
  • any breach of applicable law or regulation by you;
  • any use of your password by a third party; and
  • any breach by you of these Terms of use.
  1. Information about you

We process information about you in accordance with our Privacy Policy. By using our Services, you consent to such processing and you warrant that all data provided by you is accurate.

  1. Account access

In order to ensure that we are able to provide high-quality services that are responsive to our users’ needs, you agree that our employees may have access to your account, your Contributions and your records as reasonably needed to investigate complaints.

  1. Viruses, hacking and other offences

You must not:

  • misuse our Services by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful;
  • attempt to gain unauthorised access to our Services, the server on which our Services is stored or any server, computer or database connected to our Services; or
  • attack our Services via a denial-of-service attack or a distributed denial-of service attack, (together “Misuse”).

We may report any such Misuse to the relevant law enforcement authorities and, where we do so, we will cooperate with those authorities and may disclose your identity to them. In the event of any such Misuse, we reserve the right to suspend or terminate your use of our Services with immediate effect.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Services or to your downloading of any material posted on it, or on any website or app linked to it, except where such distributed denial-of-service attack, viruses or other technologically harmful material is caused as a result of your use of our Services in accordance with these Terms of use.

  1. Linking to our app

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

You must not establish a link from any website or app that is not owned by you.

Our app must not be framed on any other website or app, nor may you create a link to any part of our app other than the home page. We reserve the right to withdraw linking permission without notice. The website or app from which you are linking must comply in all respects with the content standards set out below.

If you wish to make any use of material on our Services other than your Contributions or the Transaction Data, please address your request to support@sylq.io.

17.Links and third parties

Where our Services contains links to other apps, websites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those apps, websites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them.

  1. Prohibited uses

You may use our Services only for lawful purposes. You may not use our Services:

  • In any way that breaches any applicable local, national or international law or regulation.
  • In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.
  • To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards set out in clause 11 above.
  • To transmit, or procure the transmission of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).
  • To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

  • Not to reproduce, duplicate, copy or re-sell any part of our app, our Services, our Software or the Content in contravention of these Terms of use.
  • Not to access without authority, interfere with, damage or disrupt:
    • any part of our app, our Services, the Software or the Content;
    • any equipment or network on which our app, our Services, the Software or the Content is stored; or
    • any equipment or network or software owned or used by any third party.

In countries where we are not permitted under applicable law to make the Services available to you, we may disable your use of some or all of the Services in those countries.

  1. Interactive services

We may from time to time provide interactive services on our app, including, without limitation, to allow users to share comments and company metrics with each other (“interactive services”).

Where we do provide any interactive service, we will provide clear information to you about the kind of service offered.

Please note that we do not monitor or moderate interactive services we provide on our Services, and, except as required by applicable law, we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

  1. Termination and suspension

The duration of this agreement will remain in effect until terminated under this clause 22. Any notice of termination of this agreement by either party is subject to the notice periods in this clause 22.

Termination for convenience: You may terminate this agreement for any reason by providing us or if you are a Referred User, the Distributor on your behalf providing at least one months’ advance notice. We may terminate this agreement for any reason by providing you at least two months’ advance notice.

Termination / suspension for cause: If you breach these terms we may:

  • temporarily or permanently withdraw your right to use our app, our Services, our Software and the Content, either with immediate effect or on notice (as determined by us acting reasonably);
  • temporarily or permanently remove any of your Contributions, either with immediate effect or on notice (as determined by us acting reasonably);
  • issue a notice to you requiring you to take certain actions and/or cease certain actions;
  • issue legal proceedings against you, including but not limited to for reimbursement of all costs on demand (including, but not limited to, reasonable administrative and legal costs) resulting from the breach; and
  • disclose such information to law enforcement authorities as we reasonably feel is necessary.

We exclude liability for actions taken in response to breaches of this agreement. The responses described above are not limited, and we may take any other action we reasonably deem appropriate.

  1. Communications under the Second Payment Services Directive (PSD2)

To the extent we are required to make communications under the PSD2 we shall either:

  • communicate general messages to you via the notifications on the website, https://sylq.io/, or through our Services; and
  • communicate messages specific to you to the email address provided by you during the registration process.

In the event of suspected fraud, we shall contact you using the contact telephone number and/or email address provided by you during the registration process.

  1. Additional terms for Direct Users required by app stores

The provisions of this clause 24 apply if you are using our app as a Direct User and using the iOS or Android versions of the app. The app, which is available on both the Apple App Store, and the Google Play Store, is controlled and offered by us from our facilities in England. The use and distribution of the app via the relevant app store is governed by the relevant app store’s own rules, with which we must both comply. In the event of a conflict between these Terms of use and the terms of the app store that you downloaded our app from, that app store’s terms shall take priority.

  1. you acknowledge that these Terms of use are between us and you only, and not with the third-party manufacturer or provider of your device or operating system (“Device Manufacturer”);
  2. you acknowledge that the Device Manufacturer has no obligation whatsoever to furnish any maintenance and support services with respect to the app;
  3. in the event of any failure of the app to conform to any applicable warranty, you may notify the Device Manufacturer, and the Device Manufacturer will refund the purchase price (if any) for the app to you and, to the maximum extent permitted by applicable law, the Device Manufacturer will have no other warranty obligation whatsoever with respect to the app;
  4. you acknowledge that us, not the Device Manufacturer, are responsible for addressing any claims of yours or any third party relating to the app;
  5. you acknowledge that, in the event of any third-party claim that the app or your use of the app infringes that third party’s intellectual property rights, the Device Manufacturer will not be responsible for the investigation, defence, settlement and discharge of any such intellectual property infringement claim;
  6. you represent and warrant that you are not located in a country that is subject to a U.S. Government embargo or that has been designated by the U.S. Government as a “terrorist supporting” country and you are not listed on any U.S. Government list of prohibited or restricted parties; and
  7. you acknowledge and agree that the Device Manufacturer, and the Device Manufacturer’s subsidiaries, are third party beneficiaries of these Terms of use, and that, upon your acceptance of these Terms of use, the Device Manufacturer will have the right (and will be deemed to have accepted the right) to enforce these Terms of use against you as a third-party beneficiary.
  1. Jurisdiction and applicable law

This agreement and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of France.

Notwithstanding the foregoing, if you are acting as a consumer (as defined under applicable laws) when entering into these Terms of use, you shall have the right to bring and defend claims in the courts located in your home jurisdiction.

  1. Variations

We may make changes to these Terms of use including any fees from time to time by posting an updated version of these Terms of use (and if applicable the fees) on our website and/or through our Services, provided we give you prior notice to such change. The amount of notice will depend on the type of changes we are making. If it affects the payment services we offer, we will give you two months’ notice. Otherwise, we can make the change by telling you beforehand. By continuing to use the website and/or our Services you are deemed to have accepted such changes. Some of the provisions contained in these Terms of use may also be superseded by provisions or notices published elsewhere on our Services.

  1. Referred Users

Each Referred User acknowledges and agrees that:

  1. the Services are provided by us and the Distributor Service is provided by the Distributor. The Services shall include the provision by us of the Transaction Data to the Distributor, so that they can use that Transaction Data as part of their Distributor Service;
  2. we shall release the Transaction Data to the relevant Distributor and the Referred User hereby consents to us doing the same;
  3. we are not responsible for any Distributor Services, including: (i) the failure or unavailability of such services; (ii) the use of Transaction Data by the relevant Distributor; and (iii) any losses which may be incurred by the Referred User in the course of receiving or relying on Distributor Services;
  4. if you have any concerns over the use or distribution of the Transaction Data by the relevant Distributor, you agree to direct your concerns to the relevant Distributor;
  5. any claim you may have in respect of the Distributor Services shall be subject to the terms of the relevant Distributor Agreement;
  6. if you have any concerns over the Distributor Services, you agree to direct your concerns to the relevant Distributor;
  7. the relevant Distributor is entirely liable for the delivery and performance (or non-delivery and non-performance) of the Distributor Services; and
  8. we will not be liable for any inaccuracy or incompleteness of any information we provide to you as part of our Services, where such inaccuracy or incompleteness arises as the result of any inaccuracy or incompleteness in any information provided by the relevant Distributor.

Where we provide the account information services, the Referred User acknowledges and agrees that the Distributor shall be responsible for providing a copy of the consolidated information to the Referred User (providing that, if the third-party provider fails to do so, the Referred User may request the same from us).

If you are a Referred User and you are unhappy with any product you have obtained from a Distributor or have any complaint regarding any Distributor Service, you should address your complaint directly to that Distributor. If you require their contact details, please tell us using the contact details set out at clause 1 and we will be happy to assist.


Prohibited Jurisdictions




American Samoa









Bosnia and Herzegovina



Burkina Faso





South Sudan




Cayman Islands

Luhansk People’s Republic


Central African Republic


Trinidad and Tobago

Crimea region





US Virgin Islands

Democratic Republic of Congo










North Korea










This list of business activities, business types or areas below are considered by Qori Merchant Services for its risk classification.

Business activities listed here are non-exclusive and provided only as a part of criteria for risk classification of a merchant and sharing of the best practices.

The risk classification will be determined under an assessment of many other relevant factors such as geographical location, countries of operations, corporate structure, legal form etc.

Qori Merchant Services will assess the risk of each Merchant in its sole discretion.

Below displayed risk matrix showcases industries, activities, types of Merchants with whom Qori Merchant Services currently will not establish business relationship.

The examples listed as “Prohibited” are disallowed while examples listed as “Restricted” would be considered by Qori Merchant Services.

Prohibited businesses, activities and types of Merchants list:

  1. Weapons, defence, military, including explosives and semi-military goods and services (like, software or technologies), Atomic Power
  2. Auction houses and bidding fee (penny) auctions
  3. Bearer Corporations
  4. Binary options and other prohibited or unlicensed financial market trading operations
  5. Carbon credits
  6. Child pornography, prostitution and escort services
  7. Merchants dealing cultural artefacts and other items of archaeological, historical, cultural and religious importance, or rare scientific value
  8. Extractive Industries (raw materials from the earth – oil, gas, metals, coal, minerals).
  9. Illegal goods and counterfeit goods
  10. Non-financial institution – foreign currency, money orders (not wire transfer) and traveller’s cheques
  11. Non-regulated Non-Profit and non- government organisations
  12. Shell banks and companies, Pawnbrokers, Ponzi / pyramid schemes
  13. Pseudo- pharmaceuticals, nutraceuticals and supplements, Smart drugs/ nootropics
  14. Political groups, and associations, embassies and consulates
  15. Unauthorised Multi-level marketing and Get-rich-quick schemes
  16. Unlicensed institutions providing financial services
  17. Unlicensed gambling/gaming, including unlicensed on-line gambling and betting
  18. Unregistered/unregulated Charities or charitable funds/institutions
  19. Merchants registered or having UBO(s) from high risk third countries which have been identified by the EU Commission, or Merchants from sanctioned jurisdiction, or jurisdiction known as terrorism supporters (in any form)
  20. Groups, legal entities, bodies, individuals and similar which have been sanctioned for major offences (offences which have entailed fines or imprisonment, and irrespective of when the Customer was sanctioned) in Lithuania or another jurisdiction
  21. Merchants where the ownership or control structure or characteristics of the entity or relationship make it difficult to identify the true owner or controlling interests or the structure is unusually extensive/complex

Restricted businesses and activities that shall be considered High-Risk:

  1. Adult entertainment, other than Child pornography, prostitution and escort services
  2. Crypto Currency Exchange, ICO Company, and any business related to/or funded by crypto currency or facilitating crypto currencies
  3. Customer who are or who has “gatekeepers” in the structure: fiduciary, independent legal professionals, tax consultants, tax advisors, auditing, notary service, escrow service
  4. Merchants where the ownership or control structure or characteristics of the entity or relationship make it difficult to identify the true owner or controlling interests or the structure is unusually extensive/complex
  5. Merchants dealing with precious metals, jewellery, gold, gems dealers (including Merchants dealing with luxurious watches)
  6. Merchants who are brokers or act as private bankers (wealth managers)
  7. Non-EU/EEA based Payment Service Providers and (digital) Money Service Business (Payment institutions, Electronic Money Institutions etc.)
  8. Importers of second-hand vehicles
  9. Legal arrangements like trusts, trust like structure, foundations, trust foundation, including legal arrangements and legal persons that are personal asset-holding vehicles
  10. Licensed land-based/offline betting, casinos, gaming machines and poker, lotteries, including online gambling
  11. Legal person or organisations without legal personality that are personal asset vehicles or/are active in asset management, brokerage
  12. Online EU tobacco, e-cigarettes and alcohol traders, CBD products
  13. Politically Exposed Persons (PEP) / PEP related persons, PEP close associates
  14. Regulated Non-Profit /Non-Governmental Organisations
  15. Registered / regulated Charities
  16. The Customer has operationally active business and provides consultancy, including IT services, lawyers,tax consultants, accountants
  17. The Customer or UBO have links or whose source of funds/wealth is linked to sectors that are commonly associated with higher corruption risk: construction, real estate, pharmaceuticals and healthcare, oil and gas, sport industries
  18. The Customer is a trust (foundation) or owned / controlled by trust (foundation) or similar legal arrangement structure (e.g. stichting)
  19. The business of Customer is cash intensive business
  20. Video Gaming, Forex service providers

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