Compliance and Financial Crime Risk Appetite Statement
Yapily maintains a zero tolerance for compliance and financial crime risk exposure, including all Money Laundering (ML) and Terrorist Financing (TF) Risk.
Yapily ensures that it adopts all regulatory, legal requirements and compliance requirements in a proportionate way that satisfies the requirements of the local regulatory authorities in a pragmatic and risk-based manner. Yapily is obliged to transact its business so as to ensure it minimises the risk of its systems and processes being used for ML or TF purposes.
Yapily has strict and transparent standards and continuously seeks to strengthen its processes to ensure compliance with all applicable laws and regulations. Yapily reserves the right to reject any client, payment, or business that is not consistent with its Risk Appetite.
Sanctions Compliance Statement
Yapily is committed to complying with the sanctions laws and regulations of the United Kingdom, European Union, the United Nations, Republic of Lithuania and the United States (the sanctions lists), as well as the applicable sanctions laws and regulations in the jurisdictions in which Yapily operates. This position is taken in order to manage regulatory, legal, operational and liquidity risks, and takes into account broader financial crime concerns.
Yapily’s internal policies prohibit or restrict dealing, directly or indirectly with parties subject to restrictive measures issued by these jurisdictions. Yapily reserves the right to refuse to engage in business involving parties with links to the sanctions lists, even where permitted by applicable sanctions laws and regulations where these activities fall outside of Yapily’s risk appetite. In some cases, this risk appetite may be stricter than our legal obligations.
PROHIBITED JURISDICTIONS
Yapily provides Account Information Services (AIS) and Payment Initiation Services (PIS) within the United Kingdom and European Union only. Yapily will not provide services to any entity or person located in the following jurisdictions:
| Jurisdiction |
|---|
| Afghanistan |
| Belarus |
| Burundi |
| Central African Republic |
| Congo, the Democratic Republic of the |
| Crimea Region |
| Cuba |
| Guinea |
| Guinea-Bissau |
| Haiti |
| Iran |
| Iraq |
| Korea, the Democratic People’s Republic of |
| Lebanon |
| Libya |
| Mali |
| Myanmar |
| Nicaragua |
| Palestine |
| Somalia |
| South Sudan |
| Sudan |
| Syrian Arab Republic |
| Ukraine |
| Venezuela |
| Western Sahara |
| Russian Federation |
| Yemen |
Prohibited Industries/activities
Yapily has defined a financial crime risk appetite that delineates the boundaries within which Yapily Connect operates. Below, we outline the prohibited and high-risk industries, setting expectations for ourselves, our clients and their merchants.
“Prohibited” industries or clients denote those we do not engage with—neither our clients nor any of their merchants can fall within this list. This list is not exhaustive, and additional considerations may apply as per our ongoing risk assessments and compliance protocols.
PROHIBITED INDUSTRIES & ACTIVITIES
| Sector |
|---|
| Sanctioned entities or individuals (United Nations, United States of America OFAC, European Union, Republic of Lithuania and United Kingdom HMT sanctions lists) |
| Adult entertainment services sold or otherwise provided on an in-person basis |
| Alternative medicines (e.g. homoeopathy) |
| Armaments, nuclear, weapons, or defence manufacturers |
| Beauty Parlours and associated activities |
| Businesses involving Manual Cash Disbursements |
| Cannabinoids (THC, CBD, CBN) |
| Chemicals and allied products |
| Commercial activity which infringes on copyrighted material |
| Companies selling timeshare |
| Companies who use drop-shipping to distribute products (business models in which the seller accepts and processes customer orders, but does not hold the stock themselves) |
| Concierge services (ad-Hoc services without a set business model, e.g. fulfilling custom client requests) |
| Consulates |
| Cyberlocker services (file sharing, file hosting, etc.) |
| Dating and escort services |
| Dating services (dating apps, matchmaking sites; coaching/advice providers to increase dating success) |
| Digital games (Merchants distributing game keys; in-app purchases within games (such as buying in-app game currencies)) |
| Diplomatic offices |
| Electronic and surveillance equipment or software (Illegal telecommunications equipment, jamming equipment, spy software or equipment; Traffic devices (radar jammers, licence plate covers, and related products); Devices/services for unlocking technical protection measures (e.g. jailbreaking iPhones/rooting Androids)). Any product designed to: Circumvent locks or other manufacturer protection features; Infringe on any DRM (including geographic & IP related restrictions) - including through a VPN or similar service; Gain access to features, media, or content the user has not paid for or been authorised to access. |
| Embassies |
| Equity funds, mutual funds, and other investment funds |
| Fake goods and counterfeit consumer products |
| Fine art dealers |
| Fortune-tellers |
| Gambling without an in-date local licence |
| Holding/Shell companies (a company that owns other companies and oversees their operations but exists solely to operate those subsidiaries) |
| Illegal goods, smuggled goods, or protected/cultural items & artefacts |
| Illegal/illicit drugs (Includes prescription drugs sold without pharmaceutical licence; Illegal substances OR substances that can be used to produce illegal substances (e.g. seeds); Substances designed to imitate illicit or illegal drugs (legal highs, research chemicals)) |
| Initial coin offering (ICO) providers where the coin could be used as a share in the firm, a prepayment voucher for future services, mode of payment in or outside the business that generated the coin |
| Invasive Medical or Surgical devices (including needles, scalpels) |
| Medical services (including needling services e.g. botox, acupuncture, tattoos). |
| Multi-level marketing - Products not sold to the customer by the manufacturer, but frequently sold to consumers via social media channels, often using recruitment and pressuring techniques |
| Nicotine/tobacco products (e.g. cigarettes, cigars, e-cigarettes, vapes, liquid for vapes/e-cigarettes) (vape hardware not included) |
| Non-licensed resellers of after market goods (e.g. non-OEM (Original Equipment Manufacturer) car parts and installers of such). Merchants selling tyres/car batteries do not need to have a licence |
| Non-licensed sellers of Apple products (merchants must be listed on the “Authorised Apple Reseller” website) |
| Non-licensed sellers of branded merchandise |
| Online resellers of high value products, where value cannot be derived from a registered quality inspection or certificate (e.g. Rolex watches, Trading cards, limited edition shoes/sneakers/trainers) |
| Pawnbrokers |
| Personal shoppers (individuals who buy items such as clothing for their customers, rather than the customer buying the item directly themselves) |
| Plants, plant seeds, fungi & fungal spores where: the plant/fungus is toxic or harmful; the seed/spore or the plant/fungus is prohibited/illegal; the plant/fungus or organism is in danger of extinction/the trade of the plant is legally regulated |
| Political organisations and institutions |
| Precious metals extraction and stone dealers |
| Professional/expertise services that come under the following: pawn shops; bodyguards/private detectives; bail bondsmen; adoption agencies; academic paper/test writing/taking services; PPI (payment protection insurance) claims services; the sale of social media likes/follows |
| Quasi-cash merchants |
| Ramp-up and ramp-down service providers that provide fiat-to-crypto exchange |
| Refurbished/second-hand electronics |
| Religious organisations |
| Remote software services/remote desktop access services |
| Sale of live animals (this includes, but is not limited to, breeding e.g. dog breeding and the sale of puppies). Includes the sale of insects, animal parts, blood, fluids |
| Secondhand car dealers not part of a national industry trade association |
| Secondhand heavy construction equipment dealers |
| Sexual services (anything which implies sex as a service) |
| Speculative Mini-Bonds |
| Special purpose vehicles (SPVs) and special purpose entities (SPEs) |
| Subscription models where the customer is buying something with a subjective outcome (based on someone’s personal satisfaction). Pseudo-pharmaceuticals (weight loss, anti-ageing, tanning, teeth whitening products, etc.) |
| Supplements (fertility boosters, testosterone boosters, diet supplements etc) making unsubstantiated claims, or claims that are impossible to verify |
| Transaction activity which displays personal information, where this violates applicable data protection laws (e.g. GDPR) |
| Trusts |
| Unregistered charitable foundations |
| Unregistered non-profit organisations/charities |
| Unregulated companies where the primary business is crypto mining, investment, or trading |
| Unregulated crowdfunding platforms |
| Unregulated Crypto ATM exchange operators that provide cash-to-crypto exchange services |
| Unregulated Cryptocurrency or Virtual Asset Providers (brokers, exchanges; FX signals providers; cryptocurrency mining services, crypto mining products (e.g. mining rigs)) |
| Unregulated custodial wallet service providers |
| Unregulated financial services (Loan lenders, payday loans companies; Debt/credit consolidation companies; Debt collection agencies) |
| Unregulated Funds (including venture capital funds) |
| Unregulated loan businesses (e.g bridging loans) |
| Unregulated Money Service Businesses (MSBs) |
| Unregulated or unregistered auction houses |
| Unregulated pension schemes |
| Unregulated money remittance businesses/Bill payment services |
| Vehicle tuning/modifications, not made by qualified personnel |
| Video game arcades and machine manufacturers |
| Weapons, such as knives and guns |