1. Introduction
This Acceptable Use Policy describes the activities, customers, and jurisdictions that we cannot support, and the activities and customers we accept only with enhanced due diligence. It forms part of your contract with Maven Pay Inc., Maven Pay Concierge Private Limited, and MavenPay Concierge Broker F.Z.E.
This policy is grounded in the Maven Pay Inc. Country Acceptance Policy, the Maven Pay Inc. AML/CTF Risk Assessment, the Maven Pay Inc. Anti-Bribery and Corruption Policy, and the Maven Pay Inc. Anti-Fraud Policy. It applies to every customer of MavenPay globally.
2. Location Risk Framework
We assess location risk using the following factors. Compliance with the recommendations of the Financial Action Task Force. Designation by the Financial Action Task Force as a high-risk or non-cooperative jurisdiction. Narcotics production or trafficking. Tax-haven status and financial secrecy. Corruption levels. International sanctions. Effectiveness of anti-money-laundering and counter-terrorism-financing measures in practice. Political stability and governance quality. Prevalence of organised crime. Economic stability.
Risk levels can change. We review our country classifications at least annually and more frequently when geopolitical events, regulatory changes, or sanctions decisions require.
3. Countries We Do Not Serve — Banned
We do not open accounts for, and we do not process payments to or from, customers who reside in, are citizens of, or are doing business in any of the following countries. There is no exception path. The list is grounded in Canadian sanctions imposed under the Special Economic Measures Act, in measures pursuant to the Justice for Victims of Corrupt Foreign Officials Act, and in decisions of the United Nations Security Council under the United Nations Act.
Belarus.
Iran.
Myanmar (Burma).
North Korea (Democratic People's Republic of Korea).
Russia.
Syria.
Ukraine — the regions of Crimea, Donetsk, and Luhansk that are temporarily occupied by Russia.
For the purposes of this section, "doing business" includes transferring money to or from banks in the listed country, investing in the listed country, providing loans or credits, importing or exporting goods, services, or technology to or from the listed country, entering into joint ventures or partnerships with entities based in the listed country, engaging in resource development or extraction in the listed country, transacting in property in the listed country, facilitating or promoting tourism to the listed country, or providing legal, financial, consulting, or engineering services to clients in the listed country.
4. Countries We Do Not Serve By Default — Prohibited
We do not open accounts for, and we do not process payments to or from, customers whose primary business location is in any of the following countries. An exception is available only on a case-by-case basis, only after enhanced due diligence is completed to our satisfaction, and only with the approval of our Compliance Officer. Exceptions are rare. The list is grounded in Canadian sanctions, in measures pursuant to the Justice for Victims of Corrupt Foreign Officials Act, and in long-standing United States Office of Foreign Assets Control restrictions where indicated.
Afghanistan. Belarus. Central African Republic. Cuba. Democratic Republic of the Congo. Haiti. Iran. Iraq. Laos. Lebanon. Libya. Mali. Myanmar (Burma). Nicaragua. North Korea. Russia, including Transnistria, Abkhazia, and South Ossetia. Somalia. South Sudan. Sudan. Syria. Ukraine — the regions temporarily occupied by Russia. Venezuela. Yemen.
For the purposes of this section, "primary business location" means the main location or headquarters where the central operations of your business are carried out, or where its senior management and key administrative functions are located.
5. Countries Where We Accept Only With Enhanced Due Diligence — High Risk
We accept customers whose residence or primary business location is in any of the following countries only after enhanced due diligence is completed. Enhanced due diligence may include additional documentation, additional verification of source of funds and source of wealth, additional sanctions and adverse-media screening, and more frequent ongoing review of the account.
Albania, Bahrain, Bangladesh, Bosnia and Herzegovina, Bulgaria, Cambodia, China, Croatia, Curaçao, Cyprus, Dominica, Guatemala, Guyana, Holy See (Vatican City State), Hong Kong, Israel, Jamaica, Jordan, Kosovo, Kuwait, Moldova, Montenegro, Nicaragua, North Macedonia, Oman, Pakistan, Palestine, Panama, Philippines, Qatar, Serbia, Sri Lanka, Turkey, Turkmenistan, Turks and Caicos, Ukraine, Vanuatu, Vietnam, West Bank.
Where a country appears on more than one list, the higher restriction applies. Where you have material connections to more than one country, we apply the restriction of the highest-risk country in that profile.
6. Ministerial Directives
We follow ministerial directives issued in the jurisdictions where we are subject to them. A ministerial directive may require us to apply additional countermeasures to transactions to or from a designated foreign jurisdiction or entity. The directives that currently apply to us include the directive of December 9, 2017 concerning the Democratic People's Republic of Korea, the directive of July 25, 2020 concerning the Islamic Republic of Iran, and the directive of February 24, 2024 concerning Russia.
7. Activities We Do Not Support — Prohibited Activity
We do not open accounts for, do not service, and do not process payments for any of the following activities. There is no exception path.
Sanctioned activity or counterparties under any sanctions regime that applies to us, including Canadian sanctions, United Nations Security Council sanctions, United States Office of Foreign Assets Control sanctions, European Union sanctions, and United Kingdom sanctions.
Money laundering, terrorist financing, and proliferation financing.
Fraud, deception, identity theft, and any activity that conceals the origin of funds.
Human trafficking, exploitation, forced labour, and modern slavery.
Child sexual abuse material.
Trade in illegal firearms, explosives, weapons of mass destruction, and dual-use items diverted from their authorised use.
Counterfeit currency, counterfeit goods, and trade in stolen property.
Privacy-coin mixers, tumblers, anonymity-enhancing services, and any virtual-asset service that allows anonymous transactions.
Darknet markets and integrations with darknet markets.
Shell banks, front companies, entities with bearer-share ownership, entities whose ultimate beneficial ownership cannot be established, and entities whose business activity cannot be verified.
Bribery, corruption, secret commissions, kickbacks, and any payment intended to influence a public official or other counterparty in their public, legal, or other duties. The applicable laws include the Canadian Corruption of Foreign Public Officials Act, the United States Foreign Corrupt Practices Act, and the United Kingdom Bribery Act.
8. Activities That Require Our Pre-Approval
We may consider accounts in the following sectors only after additional documentation and additional risk-mitigation measures are in place. Contact compliance@mavenpay.com before opening an account.
Cannabis-related businesses where federally legal and provincially licensed.
Adult content where legal in every applicable jurisdiction and where the operator can demonstrate compliance with the age-verification and consent requirements of every applicable jurisdiction.
Cryptocurrency mining at industrial scale.
Online gambling where the operator holds the relevant jurisdictional licence and where every operating jurisdiction allows the activity.
Politically exposed persons and their immediate family members and close associates, who are subject to enhanced due diligence and ongoing monitoring on every account.
Virtual-asset service providers, including exchanges, custodians, and over-the-counter desks, subject to documented evidence of regulatory licensing or registration in every operating jurisdiction.
9. Activities We Decline
Multi-level marketing.
Speculative-investment offerings sold to non-accredited customers without the approval of the relevant securities regulator.
Pyramid schemes and Ponzi schemes.
Synthetic-identity rings and account-farming operations.
10. Account Handling And Enforcement
We screen every customer at onboarding against the sanctions lists that apply to us, against politically-exposed-persons databases, and against adverse-media sources. We re-screen periodically and on every trigger event, including any change to your profile, any change to the applicable sanctions list, and any pattern in your transactions that warrants additional review.
We monitor every transaction for patterns that may indicate money laundering, terrorist financing, fraud, or identity theft, including rapid movement of funds, structuring of transactions just below reporting thresholds, transactions inconsistent with your stated purpose, transactions involving unusually complex ownership structures, and erratic volume or frequency. Where a transaction is flagged, we may pause it, ask you for additional information, ask you for documents that establish source of funds, place a hold on your account, decline the transaction, or close the account.
If you fail know-your-customer screening, if your account is funded under a name or email address other than yours and you cannot prove ownership, if you make five or more transactions in a twenty-four-hour period in a pattern inconsistent with your profile, if you contact our customer service from an email address, phone number, or messaging handle other than the one registered to your account, if your contact details or address fields do not match the supporting documents you provide, or if a counterparty bank or partner raises a fraud or compliance flag against your account, we may block transactions on your account, request a security call or additional documents, require additional sanctions or PEP screening, refer the matter to law enforcement or the relevant financial intelligence unit where the law requires, or close your account permanently.
Where the activity we identify meets the reporting threshold under the law that applies to us, we file a suspicious transaction report or equivalent report with the competent financial intelligence unit. We do not tell the customer that a report has been filed where the law prohibits us from doing so.
11. Working With Law Enforcement
We co-operate with valid law-enforcement requests and with valid requests from competent regulators and financial intelligence units. We require lawful process where the law requires lawful process, and we narrowly limit our disclosure to what the request actually requires.
12. Anti-Bribery And Anti-Corruption
Maven Pay Inc. operates under an Anti-Bribery and Corruption Policy. We do not give or accept bribes, secret commissions, or kickbacks. We do not give or accept cash, high-value items, or items for personal consumption. We may give and accept tokens of business hospitality of a normal and proportionate nature only when the item is not of significant value, is not intended to influence a decision or outcome, is publicly given or received, and is approved by management where the relevant internal control applies.
Where a customer, supplier, partner, or other counterparty offers a member of our team a prohibited gift or other inducement, the member of our team will report it to compliance@mavenpay.com.
13. Reporting A Concern
If you believe that an account on MavenPay is being used for an activity covered by this policy, or that someone has offered or accepted a bribe in connection with MavenPay, report it confidentially to compliance@mavenpay.com.
14. Contact
For any question about this policy, write to compliance@mavenpay.com.
15. Changes To This Policy
We may update this policy from time to time. When we make a material change, we will tell you in the MavenPay product or by email at least thirty days before the change takes effect. The current version of this policy and its effective date are shown at the top of this page.
