Restricted MCCs & Businesses

The adult industry refers to merchants providing pornographic audio - or video services or contents accessible via phone, the internet, or other media or channels. Clients involved in this industry are always categorised as high-risk clients.

Banking Circle does not on board and cannot facilitate payments related to child pornography or anything that suggests child pornography, including any web-site that uses associated, or possibly associated, terminology to market their product.

Banking Circle does not on board and cannot facilitate payments for clients that provide escort services and/or sale and/or advertising of sexual services.

Clients involved in selling arts and antiques, precious metals and stones, sale of vehicles or other dealing with high value goods are active in a cash intensive industry and therefore at risk of being exploited by criminals to launder the proceeds of illegitimate activities.

Companies involved in these industries are often subject to anti money laun-dering regulation when conducting sales succeeding certain amounts. Banking Circle conducts reasonable measures to ensure that such clients comply with relevant legislation, e.g. conducts COD and identifies their customers' source of funds and source of wealth.

Banking Circle cannot on board providers of binary options, CFDs and financial spread betting as they fall outside the risk appetite of Banking Circle. These products are considered inherently risky, complex and speculative and have been subject to intense scrutiny by financial authority supervisors across Europe. The European Securities and Markets Authority, ESMA, has been citing CFDs and binary options as a matter for great concern.

However, Banking Circle can under certain conditions support pay-outs to companies offering binary options, CFDs and financial spread betting as long as they possess the required licenses in the countries or territories where they are established or provide services to, as an investment service provider or as a gambling provider.

Charitable institutions, non-profit organisations and those engaged in fundraising entail an increased risk of money laundering, terrorism financing and other types of financial crime. These structures can be used as vehicles to create complex corporate structures which make it more difficult to identify the real owners and/or beneficiaries and disguise the origin of the funds

Law and accounting firms may be used knowingly or unknowingly to support money laundering, terrorism financing or other types of financial crime.

Banking Circle can on board providers of accountant and legal services, that are obliged entities under the 4th Anti-Money Laundering Directive, subject to adequate Due Diligence.

When dealing with service providers outside the EU/EEA area, Banking Circle must ensure that they are located in a jurisdiction where such entities are subject to an equal level of AML/CTF regulation.

When dealing with clients involved in the sale of drugs and pharmaceuticals, Banking Circle must be aware that different rules and regulation apply according to which jurisdictions the goods are sold to. Banking Circle must ensure that the client possesses the sufficient licensing in those jurisdictions where they are established or sell products into.

Banking Circle can conduct business only with financial services clients that are properly licensed in those countries or territories where they are established or provide services to, and that are obliged entities under EU laws or EU equivalent standards.

Illegal arms or ammunition dealing, the manufacture of such or other defence related manufactures and sales are on Banking Circle's forbidden list and clients involved in this business cannot be accepted. Firearm sales over the internet can never be accepted.

The sale of certain goods related to this industry for legitimate purposes can be accepted, e.g. knives for hunting, fishing and other relevant sports activities or for private persons.

Clients involved in this industry are always categorised as high-risk clients.

The client must hold a license in the country or territory where it is established or provides services to.

Gambling is against the law in certain countries and Banking Circle cannot support gambling related activities in countries where gambling is illegal. Due to the complex landscape within gambling, Banking Circle has adopted a specific Gambling Procedure.

Marketplace merchants should have a more than five years track record in the industry. Flows from and new marketplace platforms should as a main rule not be accepted. Goods and services sold on the marketplace must not fall with the forbidden or restricted lists and sellers subject to financial services - standard on boarding processes.