Prohibited Business Relationships Policy

1. OVERVIEW

1.1 This Prohibited Business Relationships Policy (hereinafter referred to as “Policy”) is applicable to JMS Trading Limited (Company No. C 108433), a Virtual Financial Assets Service Provider licensed by the Malta Financial Services Authority (MFSA) under the Virtual Financial Assets Act (Authorization ID – JTL – 24283) (hereinafter referred to as Company). This Policy identifies the areas where the Company based on its risk appetite refuses to enter to.

1.2 The lists in this Policy are not exhaustive and where a customer, business sector, jurisdictions or transaction type is not covered within this Policy it may be generally acceptable but will be considered on a case-by-case basis.

2. THE TERMS

2.1 The terms “jurisdiction”, “country” and “territory” may be used interchangeably throughout this Policy.

2.2 In this Policy the following terms have the below meanings:

(a) affiliated entities are the directors, shareholders, beneficial owners of corporate customer and persons authorised to act on behalf of the corporate customer.
(b) restricted jurisdictions refer to jurisdictions identified in the Appendix 1 of this Policy.

3. JURISDICTION RISK

3.1 Based on prohibitions related to jurisdiction risk, the Company shall not establish business relationship with:

Customer Type	Prohibited Relationship Conditions
Corporate Customers	Corporate customers which are residents of the Unites States of America or of any of the Group 1 and/or Group 2 Restricted Jurisdictions identified in the Appendix 1. Corporate customers which have main place of business activities, have significant targeted exposure and/or have a principal regulatory authority in any of the Group 1 and/or Group 2 Restricted Jurisdictions identified in the Appendix 1. Corporate customers having affiliated entities who are residents and/or citizens of Group 1 Restricted Jurisdictions identified in the Appendix 1.
Individual customers	Individual customers who are residents of the Unites States of America and/or Group 1 and/or Group 2 Restricted Jurisdictions identified in the Appendix 1. Individual customers who are citizens of the Unites States of America and/or Group 1 Restricted Jurisdictions identified in the Appendix 1. Individual customers whose origin of source of funds is derived from and/or whose source of wealth is maintained in the Group 1 Restricted Jurisdictions identified in the Appendix 1.

Customer Type

Prohibited Relationship Conditions

Corporate Customers

Corporate customers which are residents of the Unites States of America or of any of the Group 1 and/or Group 2 Restricted Jurisdictions identified in the Appendix 1. Corporate customers which have main place of business activities, have significant targeted exposure and/or have a principal regulatory authority in any of the Group 1 and/or Group 2 Restricted Jurisdictions identified in the Appendix 1.
Corporate customers having affiliated entities who are residents and/or citizens of Group 1 Restricted Jurisdictions identified in the Appendix 1.

Individual customers

Individual customers who are residents of the Unites States of America and/or Group 1 and/or Group 2 Restricted Jurisdictions identified in the Appendix 1.
Individual customers who are citizens of the Unites States of America and/or Group 1 Restricted Jurisdictions identified in the Appendix 1.
Individual customers whose origin of source of funds is derived from and/or whose source of wealth is maintained in the Group 1 Restricted Jurisdictions identified in the Appendix 1.

4. CUSTOMER RISK

4.1 Based on prohibitions related to customer risk, the Company shall not establish business relationship with corporate customers involved in business sectors as identified in Table 1:

Table 1 Prohibited business sectors

Business Sector	Details of Business Activities
Adult entertainment and services	– Adult goods; – Adult content, including but not limited to books, magazines, audio, videos, websites, streaming services, and other content formats deemed offensive or of a sexual nature; and – Any other services related to adult entertainment.
Ammunition, Explosive Devices and Weapons
Cannabidiol (“CBD”)	– CBD related products and businesses.
Financial Services	– Crowdfunding platforms; and – Travellers Cheques, anonymous pre-paid cards and postal money orders.
Lifetime Products	– Any type of timeshare service/product; and – Lifetime Guarantees, memberships or clubs.
Pharmaceuticals, Medical Devices and Telemedicine	– Drugs and pharmaceuticals; – Medical devices; and – Private medical practice and/or online doctor consultation.
Special Investment Opportunities	– Pyramid / Ponzi type schemes with reliance upon a continual stream of new participant; and – Get-rich-quick schemes.
Cryptoassets	-Initial coin offerings (“ICO”); and -Automated teller machines (“ATM”) and any other cryptoasset service providers allowing customer deposits and/or withdrawals in cash.
Any unlicensed, unregistered or unauthorised activity which requires licensing, registration or authorisation in its local jurisdiction, in jurisdictions where it conducts such activities or in jurisdiction(s) where the legal entities operating under the Company’s trading name operate.
Any other industry known to be an illegal industry in its local jurisdiction, in jurisdictions where it conducts its activities or in jurisdiction(s) where the legal entities operating under the Company’s trading name operate.

4.2 The Company does not establish business relationship with corporate customers whose legal form is of any of the below:

(a) trusts;
(b) legal entities such as foundations and legal arrangements similar to trusts;
(c) the below mentioned types of non-profit organizations:
- (i) charitable organisations;
- (ii) non-governmental organisations;
- (iii) religious organisations;
- (iv) clubs, societies and associations;
- (v) political parties and political organisations;
- (vi) legal aid societies, volunteer services organisations; and
- (vii) trade unions, professional bodies.

4.3 Additionally, the Company does not establish business relationship in the presence of certain risk factors listed below:

(a) Corporate customers whose share capital is issued in the form of bearer shares or that issue warrants to bearer.
(b) Individual and corporate customers subject to list-based targeted sanctions by EU, USA and/or the UK.
(c) Corporate customers which have affiliated entities subject to list-based targeted sanctions by EU, USA and/or the UK.
(d) Individual customers whose source of funds and/or source of wealth is derived from business sectors mentioned in Table 1.

5. PRODUCT, SERVICES AND DELIVERY CHANNEL RISK

5.1 Based on prohibitions related to product, services and delivery channel risk:

(a) The Company does not provide services involving privacy-focused cryptoassets (e.g. Monero, Zcash, Dash etc.)
(b) The Company does not facilitate third-party payments meaning that all customers should send payments to the Company from a financial institution account maintained in their name or should receive payments from the Company to a financial institution account maintained in their name.
(c) Customers are prohibited to receive or send payments to the Company from financial institution having its principal regulatory authority in in any of the Group 1 and/or Group 2 Restricted Jurisdictions identified in the Appendix 1.^[1]

APPENDIX 1. Restricted Jurisdictions

Group 1

Afghanistan
Belarus
Burundi
Central African Republic (the)
Congo (the Democratic Republic of the)
Cuba
Ethiopia
Guatemala
Guinea
Guinea-Bissau
Haiti
Iran (Islamic Republic of)
Iraq
Korea (the Democratic People’s Republic of)
Lebanon
Libya
Mali
Myanmar
Nicaragua
Niger (the)
Russian Federation (the)
Somalia
South Sudan
Sudan (the)
Syrian Arab Republic (the)
Yemen
Zimbabwe
Crimea
Donetsk People’s Republic
Luhansk People’s Republic
Kherson
Zaporizhzhia

Group 2

Algeria
Angola
Bolivia (Plurinational State of)
Bulgaria
Burkina Faso
Cameroon
Côte d’Ivoire
Kenya
Lao People’s Democratic Republic (the)
Monaco
Mozambique
Namibia
Nepal
Nigeria
South Africa
Venezuela (Bolivarian Republic of)
Vietnam
Virgin Islands (British)

^[1] Exemptions may apply if jurisdiction is member state of European Economic Area.

Terms of Service	Fee Policy	Business Continuity / Service Availability Statement
Privacy Policy	AML/CFT Disclosure	Acceptable Use Policy / Prohibited Activities
Cookie Policy	Complaints Handling Procedure	Risk Disclosure Statement
Conflict of Interest Policy (Summary Version)

Acceptable Use Policy / Prohibited Activities

Prohibited Business Relationships Policy

1. OVERVIEW

2. THE TERMS

3. JURISDICTION RISK

4. CUSTOMER RISK

Table 1 Prohibited business sectors

5. PRODUCT, SERVICES AND DELIVERY CHANNEL RISK

APPENDIX 1. Restricted Jurisdictions

Group 1

Group 2

Disclaimer

Risk Warning

Regulatory Status

Amendments

JMS Trading Limited