Restricted & Prohibited Business Areas
Triple-A is dedicated to promoting a safe and responsible financial ecosystem and is committed to upholding the highest standards of ethical conduct and complying with all applicable laws and regulations. To that end, this policy has been established to guide Triple-A’s partners and merchants in understanding the types of activities and products that are explicitly prohibited or subject to significant restrictions within our platform.
As such, any activity that engages in or facilitates activities that are deemed illegal or unlawful in any applicable jurisdiction is strictly prohibited. We reserve the right to prohibit any activity or product that we deem damaging to our reputation, even if it does not fall into the below categories. We undertake to comply with all applicable laws and regulations in the jurisdictions in which we operate. This means that we may have to prohibit certain activities or products based on local regulations, even if they are not explicitly listed in this policy.
At Triple-A, we welcome all legitimate businesses. However, some sectors require additional scrutiny due to their inherent risk profile. These sectors, defined as restricted, may be more susceptible to financial crime.
To ensure financial integrity and comply with international regulations, we may implement enhanced due diligence procedures for businesses in these sectors. This may include requesting additional documentation, conducting in-depth reviews, and implementing stricter monitoring practices.
This policy is not exhaustive. We reserve the right to modify this policy at any time and to make specific decisions regarding the acceptability of certain activities or products on a case-by-case basis.
Differentiated Restrictions and Prohibitions by Business Model
Restrictions
The specific restrictions and prohibitions outlined in this policy vary depending on a partner’s business model. We categorise our partners into two main groups:
1. Direct Merchant:
- A direct merchant is an entity onboarded directly to Triple-A and sells products/services in its own name and bears full responsibility for its operations.
- Additional restrictions may apply based on the merchant’s specific industry, product/service offerings, and risk profile.
2. PSP/Marketplace:
- A PSP/Marketplace is a partner who acts as a payment facilitator, enabling other entities (third-party merchants or Triple-A sub-merchants) to utilise Triple-A’s services via their platform or service.
- PSPs/Marketplaces are responsible for ensuring that all third-party merchants and sub-merchants they onboard or provide the services to comply with this policy’s restrictions and prohibitions.
- PSPs/Marketplaces are subject to heightened scrutiny and additional due diligence procedures due to their role in facilitating transactions for multiple entities.
- In addition to the general restrictions, PSPs/Marketplaces may be required to implement additional controls and monitoring mechanisms to mitigate risks associated with third-party activities.
Adult Content & Services
Merchant | PSP or | |
Services of a sexual nature on-site | Prohibited | Prohibited |
Adult content and services off-site | Restricted | Prohibited |
Regulated Substances Or Other Products And Services Presenting A Risk To Consumer Safety
Merchant | PSP or | |
CBD products | Restricted | Prohibited |
Marijuana Products | Restricted | Prohibited |
Pharmaceutical products and services | Restricted | Restricted |
Hazardous materials (B2B) e.g. peptides, research chemicals, bacteria cultures. | Restricted | Restricted |
Hazardous materials (B2C) | Prohibited | Prohibited |
Commerce of alcohol | Restricted | Restricted |
Commerce of tobacco products, including cigarettes, e-cigarettes and e-liquids | Restricted | Restricted |
Specific Legal Entities, Bodies And Structures Presenting An Increased Risk Of Bribery, Corruption And ML/TF
Merchant | PSP or | |
Shell banks | Prohibited | Prohibited |
Shell companies | Prohibited | Prohibited |
Bearer shares entities, nominee/trust structures and other similar structures designed to conceal the identity of the beneficial owner(s) | Prohibited | Prohibited |
Charities, social service organisations and other non-profit or political organisations. | Restricted | Restricted |
Embassy, consulates and other governmental institutions or services. | Restricted | Prohibited |
Other Designated Non-Financial Businesses And Professions
Merchant | PSP or | |
Art and antiques dealer | Restricted | Restricted |
Precious metals and stones dealer | Restricted | Restricted |
Used car and other first-hand vehicle dealer | Restricted | Restricted |
Other high-value goods dealer | Restricted | Restricted |
Gambling products and services | Restricted | Restricted |
Real estate services | Restricted | Restricted |
Lawyers, notaries, accountants, auditors, tax advisors and other independent legal professionals | Restricted | Restricted |
Trusts and Corporate Service Providers | Restricted | Restricted |
Financial Activities
Merchant | PSP or | |
Financial products and services including but not limited to, real estate, consumer finance, banking, insurance, payments, remittance, securities and trading | Restricted | Restricted |
Virtual Assets Service Providers | Restricted | Restricted |
Crowdfunding / Crowdlending | Restricted | Restricted |
Bidding fee auctions/penny auctions | Prohibited | Prohibited |
Sale and marketing of Binary Options | Prohibited | Prohibited |
Provider or seller of prepaid access/stored value | Restricted | Restricted |
Independent or unlicensed financial advisors | Prohibited | Prohibited |
Money Services Businesses / Money Value Transfer Services Providers / Payment Services Providers | Restricted | Prohibited |
Other Restricted And Prohibited Activities
Merchant | PSP or | |
Trade of weapons, ammunitions, military arms, explosive devices and firearm parts, other explosives and dangerous materials | Prohibited | Prohibited |
Live-streaming Services with in-app currency/donations functionality | Restricted | Restricted |
Unfair, predatory or deceptive products and services, including, but not limited to, multi-level marketing, pyramid schemes, unreasonably high reward schemes, referral marketing, etc. | Prohibited | Prohibited |
Trade in restricted and/or endangered animal species and derived products | Prohibited | Prohibited |
Human body parts or bodily fluids | Prohibited | Prohibited |
Extraction of natural resources / energy industry such as oil, natural gas, nuclear, minerals | Prohibited | Prohibited |