Prohibited & Restricted Activities Policy

Introduction

Effective Date: [●]

Last Updated: [●]

This Policy applies to merchants, businesses, customers, authorised users, developers, partners and other persons accessing or using GlocalPe's cross-border payment, international collection, foreign-exchange-related, settlement, API and related technology services (“Services”).

This Policy forms part of the GlocalPe Terms & Conditions and should be read together with the:

• KYC / KYB Policy;
• AML / CFT Policy;
• Acceptable Use Policy;
• Privacy Policy;
• Merchant / Business Terms;
• Sanctions / Country Restrictions Policy;
• applicable financial-partner requirements.

1. PURPOSE

GlocalPe seeks to prevent its Services from being used for:

• unlawful activities;
• financial crime;
• fraud;
• sanctions violations;
• prohibited goods or services;
• unauthorised financial activity;
• activities presenting unacceptable regulatory or operational risk;
• activities prohibited by GlocalPe's financial or payment partners.

The categories in this Policy are subject to applicable law and may be updated as regulatory requirements and risk conditions change.

2. PROHIBITED ACTIVITIES

The following activities are generally prohibited unless expressly permitted in writing by GlocalPe and legally permissible.

2.1 Illegal Goods and Services

GlocalPe Services must not be used for:

• illegal drugs;
• controlled substances where unlawful;
• unlawful weapons;
• explosives;
• trafficking in persons;
• stolen goods;
• goods known to be unlawfully obtained;
• counterfeit goods;
• unlawful wildlife or protected-species trade;
• other goods or services prohibited under applicable law.

3. FINANCIAL CRIME

GlocalPe Services must not be used for:

• money laundering;
• terrorist financing;
• sanctions evasion;
• fraud;
• theft;
• embezzlement;
• financial scams;
• unlawful movement of funds;
• concealment of proceeds of crime;
• concealment of beneficial ownership;
• other financial crime.

4. UNAUTHORISED FINANCIAL SERVICES

Unless expressly authorised and appropriately licensed, merchants must not use GlocalPe Services to provide:

• banking services;
• money transmission;
• payment services;
• foreign-exchange services;
• lending;
• deposit-taking;
• investment services;
• securities brokerage;
• insurance;
• other regulated financial services.

Where a business operates in a regulated sector, GlocalPe may require evidence of applicable registration, licensing or authorisation.

5. UNAUTHORISED REMITTANCE OR MONEY TRANSFER

GlocalPe must not be used as an informal or unauthorised remittance channel.

Prohibited activity may include:

• transferring funds on behalf of unrelated third parties;
• operating an undisclosed money-transfer business;
• facilitating informal value-transfer arrangements;
• receiving money for onward transmission without an approved business purpose;
• structuring transactions to disguise remittance activity.

6. MONEY MULE ACTIVITY

GlocalPe Services must not be used to:

• receive funds on behalf of unknown or undisclosed persons;
• move funds through personal or business accounts for third parties;
• provide accounts for pass-through transactions;
• receive or transfer suspected proceeds of crime;
• facilitate money-mule arrangements.

7. FRAUDULENT BUSINESSES

GlocalPe may reject or prohibit businesses that:

• impersonate another company;
• operate using false identities;
• provide materially false information;
• use fake websites;
• use forged documents;
• misrepresent goods or services;
• operate fraudulent investment or financial schemes;
• engage in deceptive customer practices.

8. PYRAMID AND ILLEGAL PONZI SCHEMES

GlocalPe Services must not be used for:

• Ponzi schemes;
• unlawful pyramid schemes;
• fraudulent investment schemes;
• guaranteed-return schemes that are unlawful;
• deceptive referral structures;
• other schemes primarily dependent on recruitment rather than legitimate goods or services.

Legitimate multi-level or referral businesses may be subject to enhanced review depending on applicable law and risk.

9. GAMBLING AND GAMING

Gambling, betting and gaming businesses may be subject to significant legal and regulatory restrictions.

GlocalPe may prohibit or restrict:

• online gambling;
• sports betting;
• casino services;
• betting exchanges;
• lotteries;
• gaming involving monetary stakes;
• gambling-related payment flows.

A business may only be considered where:

• the activity is lawful in the relevant jurisdictions;
• all required licences are held;
• applicable financial-partner requirements are satisfied;
• GlocalPe has expressly approved the activity.

10. VIRTUAL DIGITAL ASSETS / CRYPTOCURRENCY

Activities involving:

• cryptocurrency;
• virtual digital assets;
• token sales;
• exchanges;
• wallets;
• digital-asset brokerage;
• crypto investment platforms;
• mining-related services;

may be prohibited or subject to enhanced review.

Approval, where possible, may depend on:

• applicable law;
• regulatory status;
• jurisdiction;
• business model;
• financial-partner requirements;
• GlocalPe risk assessment.

11. INVESTMENT AND TRADING SERVICES

Businesses providing:

• investment products;
• securities;
• brokerage;
• trading platforms;
• binary options;
• derivatives;
• leveraged trading;
• foreign-exchange trading platforms;
• investment advisory services;

may be restricted or prohibited unless appropriately authorised and approved.

12. LENDING AND CREDIT

Businesses involved in:

• lending;
• loan origination;
• credit brokerage;
• debt collection;
• payday lending;
• buy-now-pay-later;
• peer-to-peer lending;

may require additional regulatory review.

Unlicensed lending or deceptive credit practices are prohibited.

13. INSURANCE

Insurance-related activities may be subject to applicable licensing and regulatory requirements.

Unlicensed insurance solicitation, brokerage or underwriting is prohibited.

Licensed businesses may be subject to enhanced review and approval.

14. ADULT-ORIENTED BUSINESSES

Businesses involving adult-oriented products or services may be restricted or prohibited depending on:

• applicable law;
• jurisdiction;
• payment-network requirements;
• financial-partner requirements;
• GlocalPe risk appetite.

Any activity involving exploitation, trafficking, non-consensual content or minors is strictly prohibited.

15. HEALTHCARE AND PHARMACEUTICALS

Businesses involving:

• pharmaceuticals;
• medical products;
• healthcare services;
• telemedicine;
• supplements;
• medical devices;

may be subject to enhanced review.

Businesses must hold all licences and approvals required by applicable law.

Illegal or unapproved medicines, controlled substances or deceptive medical products are prohibited.

16. HIGH-VALUE GOODS

Businesses dealing in high-value goods may be subject to enhanced due diligence.

This may include:

• precious metals;
• jewellery;
• gemstones;
• luxury goods;
• high-value electronics;
• collectibles;
• other high-value goods.

Additional transaction documentation may be required.

17. PRECIOUS METALS AND GEMSTONES

Businesses dealing in:

• gold;
• precious metals;
• diamonds;
• gemstones;
• bullion;

may be subject to enhanced review due to financial-crime and cross-border trade risks.

Transactions may require additional information regarding:

• source;
• supplier;
• buyer;
• invoices;
• shipment;
• valuation;
• underlying commercial purpose.

18. CHARITIES AND FUNDRAISING

Charitable organisations, crowdfunding platforms and fundraising activities may be subject to enhanced review.

GlocalPe may require:

• legal registration;
• charitable status;
• beneficiary information;
• purpose of funds;
• source and destination of funds;
• supporting documentation.

Fundraising for unlawful organisations or prohibited purposes is strictly prohibited.

19. POLITICAL AND CAMPAIGN-RELATED ACTIVITIES

Political organisations, campaign activities and politically connected businesses may be subject to enhanced due diligence.

GlocalPe may require additional information regarding:

• legal status;
• funding purpose;
• source of funds;
• beneficiaries;
• authorised representatives;
• applicable regulatory requirements.

Activities prohibited by applicable election, campaign-finance or other laws are prohibited.

20. ADULT SERVICES AND SEXUAL EXPLOITATION

GlocalPe may restrict or prohibit certain adult-oriented services based on applicable law, partner requirements and risk considerations.

Any activity involving:

• minors;
• sexual exploitation;
• trafficking;
• non-consensual sexual content;
• forced services;

is strictly prohibited.

21. ILLEGAL CONTENT

GlocalPe Services must not be used to sell, distribute or monetise:

• unlawful content;
• content involving exploitation;
• stolen intellectual property;
• unlawful surveillance;
• illegal access credentials;
• other unlawful materials.

22. COUNTERFEIT AND INTELLECTUAL-PROPERTY INFRINGEMENT

Businesses must not use GlocalPe Services for:

• counterfeit branded goods;
• fake documents;
• unauthorised replicas;
• pirated software;
• pirated media;
• stolen intellectual property;
• other materially infringing goods or services.

Merchants may be required to demonstrate the legitimacy of their products.

23. WEAPONS

GlocalPe generally prohibits transactions involving unlawful:

• firearms;
• ammunition;
• explosives;
• prohibited weapons;
• weapon components;
• weapons-related services.

Lawful businesses dealing in regulated goods may be subject to additional review and may still be declined based on applicable partner or payment-network restrictions.

24. DRUGS AND CONTROLLED SUBSTANCES

Transactions involving illegal drugs or unlawful controlled substances are prohibited.

Legitimate pharmaceutical or healthcare businesses may be subject to additional licensing and compliance requirements.

25. TRAFFICKING AND EXPLOITATION

GlocalPe strictly prohibits use of its Services for:

• human trafficking;
• forced labour;
• sexual exploitation;
• child exploitation;
• slavery;
• recruitment for exploitative purposes.

Any suspected activity may be escalated to appropriate authorities where required.

26. WILDLIFE AND ENVIRONMENTAL CONTRABAND

Transactions involving unlawful trade in:

• protected wildlife;
• endangered species;
• prohibited animal products;
• illegal timber;
• other environmental contraband;

are prohibited.

27. SANCTIONS AND RESTRICTED JURISDICTIONS

GlocalPe may prohibit transactions involving:

• sanctioned persons;
• sanctioned entities;
• sanctioned jurisdictions;
• restricted countries;
• prohibited counterparties;
• transactions intended to evade sanctions.

Applicable restrictions may arise from:

• Indian law;
• applicable foreign laws;
• financial-partner requirements;
• payment-network requirements;
• GlocalPe risk controls.

28. TRADE AND EXPORT-CONTROLLED GOODS

Cross-border transactions involving goods or services subject to:

• export controls;
• import restrictions;
• trade embargoes;
• licensing requirements;
• customs restrictions;

may be restricted or prohibited.

Merchants are responsible for obtaining all required approvals and complying with applicable trade laws.

29. TAX EVASION

GlocalPe Services must not be used to:

• conceal taxable income;
• falsify invoices;
• misrepresent transaction values;
• disguise beneficial ownership;
• evade applicable taxes;
• structure transactions primarily to avoid lawful tax obligations.

30. SHELL COMPANIES AND NOMINEE ARRANGEMENTS

GlocalPe may reject businesses that appear to be:

• shell entities without a legitimate commercial purpose;
• nominee arrangements intended to conceal ownership;
• entities established primarily to move funds;
• entities whose beneficial ownership cannot be reasonably established.

Legitimate holding or special-purpose structures may be subject to enhanced due diligence.

31. THIRD-PARTY PROCESSING

Merchants must not use their GlocalPe account to process transactions belonging to another business unless expressly authorised.

A merchant must not:

• operate as an undisclosed sub-aggregator;
• process transactions for unrelated businesses;
• pool funds for third parties;
• disguise the identity of the actual merchant.

RBI's PA framework specifically addresses merchant due diligence and requires appropriate controls around merchants and sub-aggregator arrangements.

32. PERSONAL REMITTANCES

GlocalPe business accounts must not be used for personal remittances or personal fund transfers unless the relevant Service expressly permits such use.

Transactions must have a legitimate and properly documented underlying purpose.

33. CASH-EQUIVALENT AND PASS-THROUGH TRANSACTIONS

GlocalPe may prohibit transactions that appear primarily designed to:

• move funds without genuine commerce;
• provide informal banking;
• transfer value between unrelated parties;
• circumvent financial controls;
• create artificial transaction volume.

34. HIGH-RISK BUSINESS MODELS

The following may be subject to enhanced review:

• marketplaces;
• payment facilitators;
• aggregators;
• intermediaries;
• referral networks;
• dropshipping businesses;
• high-volume digital businesses;
• cross-border marketplaces;
• businesses with complex ownership;
• businesses operating across multiple high-risk jurisdictions.

Additional documentation may be required before approval.

35. COMPLEX CROSS-BORDER STRUCTURES

Businesses involving multiple entities, jurisdictions, payment routes or settlement arrangements may be subject to enhanced review.

GlocalPe may request:

• group structure;
• ownership information;
• inter-company agreements;
• invoices;
• contracts;
• flow-of-funds diagrams;
• settlement arrangements;
• regulatory licences.

36. RESTRICTED ACTIVITIES

The following categories are not automatically prohibited but may require prior written approval and enhanced due diligence:

Category

Typical Additional Review

Regulated financial services

Licence / regulatory status

VDA / crypto-related activity

Legal and regulatory assessment

Gambling / gaming

Licence and jurisdiction review

Investment services

Regulatory authorisation

Lending / credit

Licence and business-model review

Insurance

Regulatory authorisation

Pharmaceuticals

Applicable licences

Healthcare

Regulatory compliance

Charities / fundraising

Registration and fund purpose

Political / campaign activity

Legal and source-of-funds review

Precious metals / gems

Source, trade and transaction review

High-value goods

Enhanced transaction documentation

Complex marketplaces

Merchant / fund-flow review

High-risk jurisdictions

Enhanced sanctions / AML review

Approval is not guaranteed.

37. APPROVAL DOES NOT CREATE A LICENCE

Approval by GlocalPe to process a particular business or activity does not:

• create a regulatory licence;
• authorise unlawful activity;
• replace a licence required by law;
• represent regulatory approval by GlocalPe.

The merchant remains responsible for obtaining all required licences and approvals.

38. MERCHANT RESPONSIBILITY

Merchants are responsible for ensuring that:

• their goods and services are lawful;
• their business is accurately described;
• required licences are maintained;
• transaction information is accurate;
• their customers receive required disclosures;
• their use of GlocalPe remains within the approved business activity.

39. DUE DILIGENCE

GlocalPe may conduct due diligence before and after onboarding.

This may include:

• website review;
• business verification;
• ownership verification;
• sanctions screening;
• transaction review;
• regulatory-status verification;
• adverse-information screening;
• ongoing monitoring.

A self-declaration alone may not be sufficient where additional verification is reasonably required. RBI materials on PA merchant onboarding emphasise due diligence beyond merely obtaining merchant declarations.

40. TRANSACTION MONITORING

GlocalPe may monitor transactions for:

• prohibited activity;
• restricted activity;
• financial crime;
• sanctions;
• fraud;
• unusual activity;
• activity inconsistent with the approved business profile.

41. TRANSACTION HOLDS

GlocalPe may delay, hold or reject a transaction where:

• the underlying activity requires review;
• additional documentation is required;
• a sanctions alert is generated;
• prohibited activity is suspected;
• financial-crime concerns arise;
• a partner declines processing;
• applicable law prevents processing.

42. ACCOUNT SUSPENSION

GlocalPe may suspend or restrict an account where it reasonably believes that:

• prohibited activity is occurring;
• restricted activity has not been approved;
• information is false or misleading;
• applicable law may be violated;
• financial-crime risk exists;
• continued access creates material risk.

43. TERMINATION

GlocalPe may terminate a relationship where:

• prohibited activity is identified;
• required approval cannot be obtained;
• material policy violations occur;
• applicable law or partner requirements require termination;
• the merchant fails enhanced due diligence;
• continued processing presents unacceptable risk.

44. POLICY CHANGES

GlocalPe may add, remove or modify prohibited or restricted categories based on:

• changes in law;
• regulatory requirements;
• sanctions;
• payment-network rules;
• financial-partner requirements;
• emerging fraud patterns;
• changes in risk appetite;
• changes in GlocalPe Services.

The latest version of this Policy will apply from its stated effective date.

45. NO EXHAUSTIVE LIST

The categories in this Policy are intended to provide guidance and are not necessarily exhaustive.

GlocalPe may restrict or prohibit a business, transaction or activity where it reasonably determines that the activity:

• creates material legal or regulatory risk;
• creates unacceptable financial-crime risk;
• conflicts with partner requirements;
• threatens the security or integrity of the Services;
• is otherwise inappropriate for the GlocalPe ecosystem.

46. COMPLIANCE WITH APPLICABLE LAW

Nothing in this Policy permits an activity that is prohibited by applicable law.

Where applicable law imposes a stricter requirement than this Policy, the legal requirement will prevail.

47. CONTACT

Questions concerning whether a particular business or activity is permitted may be directed to:

Compliance Contact: [●]

Merchant Risk Contact: [●]

Legal Contact: [●]

Email: [●]

Registered Office: [●]

Website: [●]

Policy Version: [●]

Effective Date: [●]

Last Updated: [●]