Prohibited Business

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Customer Acceptance Policy
Version History

Version  Changes Author Board approval date 
1.0 Original document Chakree Chankana 1 Sep 2019
2.0 Original document Chakree Chankana 9 Nov 2020

Policy Review

This policy (the “Policy”) is reviewed annually by the board of directors.

Customer On-Boarding Requirements
Who is the Customer?

The customer (the “Customer”) is the entity with whom the Company intends to hold a contract for the provision of consulting services.
Generally, this will be a limited company or a limited liability partnership. In certain cases, this may be a private individual.

The Customer
Key Business Details

As a minimum, the Company shall collect all information as required by the Company’s AML/CTF policies and procedures.

Customer Sign-Off

A new Customer’s file must be reviewed and sign-off by a member of the Company’s compliance team. Where the compliance team member is not
satisfied with the details provided, notwithstanding the automatic rejection criteria below, they shall undertake additional due diligence
on the Customer.

Rejection Criteria
The Customer will be rejected automatically in the following situations:

• Customer is listed on an international sanctions list (e.g. OFAC)
• Any individual connected with the Customer is identified as a PEP
• Any individual connected with the Customer is listed on an international sanctions list (e.g. OFAC)
• Customer or any individual/legal entity associated or any other with the Customer is engaged in any of the prohibited activities listed in Schedule 1
• Customer is based in a jurisdiction with a high risk of money laundering

Schedule 1: Prohibited Industries

• Adult entertainment including dating and escort services
• Agencies recruiting foreign workers in the UK
• Binary options trading
• Bitcoin/digital currency issuers Bonded warehouses
• Crowd funding
• Debt management and collection Defence
• Development aid
• Diamond and precious metal merchants, including jewellers Embassies
• Energy
• File sharing
• Gambling
• Investments
• Life science and experimental companies
• Mining companies involved in exploration and extraction
• Non-UK registered companies
• Nutrition and pharmaceuticals
• Online forex trading, including managed forex accounts
• Pay day lenders
• Political parties, pressure groups and think tanks
• Private security firms
• Unregistered charities (i.e. not registered with the Charity Commission)
• Offshore bank transactions/ Shell banks
• Remittances funded in cash; Cash and Check Handling: Check Cashing, Deposit Taking, Cash Transfer.
• Companies formed of Bearer Shares
• Shell companies
• Fourth party payment & multi-layered MSB arrangements
• Transactions for goods subject to export prohibition/restrictions
• Transactions with living animals (exceptions possible like for payments for horse riding, or dog classes)
• Political / religious organisations engaged in hate speech
• Sanctioned entities



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