Prohibited and Restricted Activities

1. Prohibited activities

PREFLOOR LTD does not connect and does not facilitate the provision of payment solutions to merchants whose activity involves:

• child sexual abuse material or other content sexualising minors;
• human trafficking, forced labour or the unlawful trade in human organs;
• terrorism, terrorist financing, or activity involving persons, organisations, territories or programmes subject to applicable sanctions restrictions;
• the unlawful circulation of narcotic drugs, psychotropic substances, controlled substances and new psychoactive substances outside a lawful pharmaceutical or other authorised channel;
• the unlawful trade in weapons, ammunition, explosives and other goods whose circulation is prohibited or materially restricted by applicable law;
• financial pyramids, Ponzi schemes, matrix schemes, unlawful high-yield investment programmes and other similar fraudulent models;
• fraudulent, deceptive or misleading offerings, including counterfeit goods, forged documents and other unlawful goods or services;
• ransomware, malware, unlawful trade in credentials or payment card data, botnets, unlawful hacking services and other unlawful cyber activity;
• money laundering, terrorist financing, concealment of the origin of funds or other activity aimed at legalising the proceeds of crime;
• the provision of payment, financial, investment or other regulated services without the required licence, registration or permission where applicable law imposes such a requirement;
• the processing of payments or transfer of funds on behalf of undisclosed third parties, or the use of arrangements designed to conceal the actual merchant or recipient of funds;
• systematic or material infringement of intellectual property rights;
• the unlawful trade in wildlife, protected species or other items whose circulation is prohibited by law.

2. Restricted activities requiring additional review

The following activities may be considered by PREFLOOR LTD on a case-by-case basis, taking into account applicable law, the risk level, the availability of the required licences or permissions where these are required, and the requirements and risk appetite of the relevant licensed payment partner:

• online gambling, betting, casinos, lotteries and other forms of gambling;
• trading platforms, brokerage services, forex, CFDs and other investment or financial products;
• cryptocurrency exchanges, virtual asset services, fiat-to-crypto and crypto-to-fiat services, and custodial wallets;
• lending, consumer credit, factoring, BNPL and other credit products;
• pharmacies, telemedicine, prescription medicines and other regulated medical products or services;
• tobacco products, nicotine products and alcohol;
• lawful adult content, subject to age verification and the consent of all participants;
• dating and communication services, where the business model or risk profile requires additional review;
• nutraceuticals, food supplements, health-related products and goods carrying medical or other regulated claims;
• debt collection and credit repair;
• travel, ticketing and other services with a long period between payment and actual delivery;
• charitable, public or political fundraising;
• other activities that PREFLOOR LTD or the relevant licensed payment partner classifies as higher risk.

Classification of an activity into one of these categories does not in itself mean automatic refusal of connection.

3. Additional review

As part of additional review, PREFLOOR LTD may request from the merchant information and documents, including:

• corporate and registration documents;
• licences, permissions and registrations, where required by applicable law;
• information on the ownership structure and beneficial owners;
• information on the business model, goods and services;
• details of the countries and markets of operation;
• an operating website or other sales channels used;
• a description of the customer journey, payment process, refunds and complaint handling;
• chargeback, refund and fraud history;
• information on key suppliers, counterparties or other participants in the business model;
• Source of Funds and/or Source of Wealth of beneficial owners, where such review is justified by the level of AML, sanctions, fraud or other compliance risk;
• other documents and information reasonably necessary for the review.

The merchant is solely responsible for identifying and complying with the licensing, registration and other requirements applicable to its activity.

PREFLOOR LTD carries out its review on the basis of the information and documents provided by the merchant and other available information, and does not warrant the lawfulness of the merchant's activity in every jurisdiction in which it operates.

4. Jurisdictional restrictions

The possibility of connection is determined in light of the specific jurisdiction, the type of activity, the business model used and the relevant payment corridor.

An activity that is permitted in one jurisdiction may be prohibited, restricted or subject to licensing in another.

Connection also depends on the requirements, restrictions and risk appetite of the relevant licensed payment partner.

Sanctions and other compliance checks may extend to the merchant, its beneficial owners, directors, controlling persons and other relevant participants in the business model, to the extent necessary under applicable law, partner requirements and the assessed risk level.

5. Business model and merchant conduct

Beyond the type of activity, PREFLOOR LTD takes into account the actual business model and the way the merchant interacts with its customers.

PREFLOOR LTD may refuse connection or take other measures in respect of models associated with material consumer harm, fraud or deceptive practices, including:

• hidden or misleading subscriptions;
• automatic conversion of a trial period into a paid subscription without proper notice;
• creating unreasonable obstacles to cancelling a subscription or obtaining a refund;
• misleading prices, tariffs, terms or descriptions of goods and services;
• the use of deceptive or misleading advertising;
• concealment of material information from customers or from PREFLOOR LTD;
• use of payment infrastructure otherwise than in accordance with the declared business model.

6. Measures where risk or breach is identified

Where PREFLOOR LTD identifies prohibited activity, a material discrepancy with previously provided information, concealment of material circumstances or other unacceptable risk, PREFLOOR LTD may, depending on the nature and level of risk:

• request additional documents and information;
• impose additional conditions or restrictions;
• refuse connection;
• restrict or suspend the provision of the relevant services;
• suspend the referral or routing of transactions;
• pass the relevant information to a licensed payment partner where permitted by applicable law and contractual terms;
• terminate the business relationship with the merchant.

The provision of false, incomplete or misleading information during onboarding, due diligence or ongoing monitoring may itself be grounds for refusal of connection, suspension or termination of the business relationship.

Where a licensed payment partner is involved in the provision of services, the merchant may also be subject to that partner's requirements under the relevant contractual terms, including restrictions, reserves, withholdings, additional checks and settlement particularities.

7. The list is not exhaustive

This list of prohibited and restricted activities is not exhaustive.

PREFLOOR LTD may refuse connection, restrict or discontinue further service in respect of activity that, in the reasonable assessment of PREFLOOR LTD or of the relevant licensed payment partner, creates unacceptable regulatory, sanctions, AML/CTF, fraud, chargeback, consumer protection, reputational or other material risk.

PREFLOOR LTD may also refuse connection where the activity concerned is not accepted by the available licensed payment partners.

8. Enquiries before connection

If a merchant is unsure whether its business model falls into a prohibited or restricted category, we recommend contacting PREFLOOR LTD before starting the connection procedure.

For a preliminary assessment, please provide a description of the product or service, the markets of operation, the customer journey, the payment model and any licences or permissions held, where applicable.

A preliminary assessment by PREFLOOR LTD is not a guarantee of subsequent connection, as the final possibility of service depends on the outcome of due diligence, applicable law and the requirements of the relevant licensed payment partner. Write to business@prefloorltd.com.