Customer Acceptance Policy
Introduction
RAGAPAY’S Customer Acceptance Policy defines the use and limitations of its services. It covers both Personal and Corporate customers across various business sectors, countries, and transaction types, evaluating them on a case-by-case basis. The policy is adaptive, allowing for restrictions or prohibitions under certain circumstances.
Definitions
- Prohibited: Activities or entities not accepted under any scenario.
- Restricted: Activities or entities subject to approval, evaluated individually.
- Permitted: Generally acceptable activities or entities, barring specific exceptions.
Jurisdictions
Prohibited Jurisdictions
Our services cannot be extended to individuals or entities based in countries identified on our prohibited list. This restriction also applies to beneficial owners or directors from these locations, with potential exceptions subject to approval by our Banking Partner’s MLRO. The list further encompasses any nation enforcing ‘Capital Control’ laws.
Country Code
| Afghanistan | AF |
| American Samoa | AS |
| Angola | AO |
| Bangladesh | BD |
| Barbados | BB |
| Benin | BJ |
| Guinea-Bissau | GW |
| Bolivia | BO |
| Botswana | BW |
| Brunei | BN |
| Burkina Faso | BF |
| Burundi | BI |
| Central African Republic | CF |
| Dominica | DM |
| Ivory Coast (Côte d’Ivoire) | CI |
| Djibouti | DJ |
| Eritrea | ER |
| Ethiopia | ET |
| Fiji | FJ |
| Gabon | GA |
| Guyana | GY |
| Gambia | GM |
| Ghana | GH |
| Guam | GU |
| Guinea | GN |
| Haiti | HT |
| Honduras | HN |
| Iraq | IQ |
| Iran | IR |
| U.S. Virgin Islands | VI |
| Jamaica | JM |
| Yemen | YE |
| United States Minor Outlying Islands | UM |
| Cayman Islands | KY |
| Christmas Island | CX |
| Cambodia | KH |
| Cameroon | CM |
| Kyrgyzstan | KG |
| Kiribati | KI |
| Congo | CG |
| Democratic Republic of the Congo | CD |
| Kosovo | XK |
| Crimea | UA |
| Cuba | CU |
| Laos | LA |
| Lesotho | LS |
| Lebanon | LB |
| Liberia | LR |
| Libya | LY |
| Madagascar | MG |
| Malawi | MW |
| Maldives | MV |
| Mali | ML |
| Mauritius | MU |
| Mauritania | MR |
| Myanmar | MM |
| Micronesia | FM |
| Mongolia | MN |
| Mozambique | MZ |
| Namibia | NA |
| Nauru | NR |
| Nigeria | NG |
| Niger | NE |
| Nicaragua | NI |
| Niue | NU |
| Pakistan | PK |
| Palau | PW |
| Palestinian Territories | PS |
| Panama | PA |
| Papua New Guinea | PG |
| South Sudan | SS |
| Pitcairn Islands | PN |
| French Southern Territories | TF |
| Equatorial Guinea | GQ |
| Rwanda | RW |
| Russia | RU |
| East Timor (Timor-Leste) | TL |
| Samoa | WS |
| São Tomé and Príncipe | ST |
| Senegal | SN |
| Sierra Leone | SL |
| Syria | SY |
| Somalia | SO |
| Sudan | SD |
| Eswatini (Swaziland) | SZ |
| Tajikistan | TJ |
| Tanzania | TZ |
| Turks and Caicos Islands | TC |
| Togo | TG |
| Tokelau | TK |
| Tonga | TO |
| Trinidad and Tobago | TT |
| Turkmenistan | TM |
| Tuvalu | TV |
| Uganda | UG |
| Western Sahara | EH |
| Vanuatu | VU |
| Vatican City (Holy See) | VA |
| Venezuela | VE |
| Zambia | ZM |
| Zimbabwe | ZW |
| Chad | TD |
| North Korea (Democratic People’s Republic of Korea) | KP |
| Sri Lanka | LK |
Prohibited Activities
- Commercial logging operations or purchase of logging equipment for use in the primary tropical moist forest;
- Creation of indecent and obscene material including child pornography;
- Diamond trading without Kimberley Certification;
- Drift net fishing in the marine environment using nets above 2.5km in length;
- Drug trafficking includes chemicals used to manufacture a synthetic drug or drugs;
- Giving or receiving gifts that could be interpreted as intending to influence business decisions;
- Illegal use of confidential material and non-public information;
- Involvement in any business relating to prostitution;
- Money exchange dealings;
- Non-licensed forex/binary options;
- Non-licensed offline gambling/betting/casino/horse racing/bingo/sports betting;
- Non-licensed online casino/online poker/online gambling/online betting/prize draws/gift cards/any form of lottery/scratch cards;
- Production or activities involving harmful or exploitative forms of forced labor /harmful child labor;
- Production or trade in any product or activity deemed illegal under host country laws or regulations or international conventions and agreements, including without limitation host country requirements related to environmental, health and safety, and labor aspects;
- Production or trade in ozone-depleting substances subject to international phase-out;
- Production or trade in pesticides/herbicides subject to international phase-outs or bans;
- Production or trade in pharmaceuticals subject to international phase-outs or bans;
- Production or trade in radioactive materials;
- Production or trade in weapons and munitions;
- Production or trade in wood or other forestry products from unmanaged forests;
- Production, trade, storage, or transport of significant volumes of hazardous chemicals, or commercial scale usage of hazardous chemicals;
- Quarries, mining, or processing of metal ores or coal;
- Trade in wildlife or wildlife products regulated under CITES;
- Trading of animal fur, bones, and ivory;
- Trading of bearer shares and bonds;
- Trading of cultural objects like sculptures, statues, antiques, collectors’ items, and archaeological pieces especially those originating from the Republic of Iraq;
- Trading of fireworks, explosives, and weapons;
- Trading in derivatives/options/hedging;
- The dealing of jewels, gems, and precious metals.
Restricted Jurisdictions
Individuals or entities from jurisdictions not explicitly mentioned may still be eligible for our services, which are evaluated individually. The Compliance team will assess such onboarding applications, especially focusing on those with payment needs in major markets including the US, Canada, and UK
Certain customer types are identified as carrying a higher level of risk, necessitating further due diligence. Should there be limitations on publicly available information or if the risk is considered too high, such customers will not be permitted to engage in transactions with us.
Type of Legal Entity
Permitted Legal Entities
- Limited Liability Companies (‘LTD’)
- Public Listed Companies (‘PLC’)
Prohibited Legal Entities
Customers cannot be accepted where the legal form of the contracting entity is:
- Unregistered charity or foundation
- A company with bearer shares
- Shell Companies
- LLP Form
- US entities with no Substance
Restricted Legal Entities
Customers are restricted where the legal form of the contracting entity is:
- Private/Limited Partnerships
- Registered Charity or Foundation – additional due diligence is required
- Sole proprietor/trader – additional due diligence will be required
- A trust – additional due diligence is required to ensure that the trust’s beneficial owners are appropriately identified and verified and that the trust is not being used as a vehicle to illegally evade the payment of tax
- Private equity funds/special purpose vehicles/sovereign wealth funds or any other legal entity other than a conventional limited liability company or public limited company – any specialist structures other than a normal trading company/PLC fall outside the Compliance Department’s normal onboarding policies and will need to be scoped before any commercials are agreed. Additional time for onboarding is likely to be required
- Companies pending incorporation or legal registration – proof of application with the relevant authorities must be provided
Business Sector
RAGAPAY does not offer services to entities engaged in the following types of activities or services:
Business Sector Activity/Service
| Adult/Dating | Escort/Prostitution Agencies
Pornography featuring children, rape, humiliation, or bestiality C2B Adult Content Any other form of pornography depicting sexual intercourse C2B |
| CBD | Marijuana dispensaries
Peripheral products / services that support illegal activities (drug paraphernalia including seeds for cannabis plants etc.) |
| Pharmaceuticals | Any type of distribution of Medical products
Drug-related paraphernalia, e.g., selling bongs, hookahs Illegal/synthetic drugs or prescription drugs without a prescription Sites selling pharmaceuticals without a prescription (cancer drugs, steroids, etc.) |
| Speciality Retail | Counterfeit goods Human body parts
Offensive goods related to crime, e.g. photographs memorabilia Weapons (including firearms) Tobacco & Electronic cigarettes Pyrotechnic devices and hazardous materials, e.g. fireworks, explosives, toxic/flammable goods Animals and Livestock Stolen Property Police-related items Mailing lists and personal information Government documents and IDs Lock picking devices |
| Arms and ammunition | Wholesale and retail distribution of firearms and ammunition. Export and import of arms and ammunition internationally. Supplying weapons to law enforcement, military, and private security firms. |
| Cyberlockers | Offer rewards, cash payments, or other incentives to users. They provide URL codes to uploaders, making it easier to share files and include these links on third-party indexing or linking websites. Typically, file owners remain anonymous, aren’t required to provide identifying information, and are unaware of the identities of users who access or view their files. |
| High-Pressure Sales | Involve unsolicited vendors demanding immediate payment or threatening price increases. This tactic often targets vulnerable customers, exploiting their worries and concerns. |
| Illegal Activity | The sale of any illegal products or services is strictly prohibited. All products must be legal in both the merchant’s jurisdiction and the consumer’s jurisdiction, especially when goods are shipped across borders. |
| Illegal Products/Services (including, but not limited to the following) | Designer drugs and street drugs, which are synthetic or chemical analogues of controlled substances, are intended to mimic their psychoactive or stimulating effects. Examples include peptides, K2, and Salvia Divinorum, which may be marketed as incense, potpourri, or bath salts. |
| Penny Auctions: | Purchasing bid credits Open-ended auctions |
| Others :- | Airlines Online Travel Aggregators (OTAs) Ticketing agencies Others Gig economy Gold and precious metal dealers Import / Export businesses Marketplaces Products or services related to religious, political, or social campaigning Remote computer assistance Maritime/logistics/supply chain Signal jammers/blockers that interfere with cellular/communication devices Tattoo parlors E-learning, online tuition Bankruptcy lawyers Livestreaming Auctions |
| Wildlife Trade Mail Order Brides Poisonous or Hazardous Materials Surrogacy Services Trade of Weapons, Ammunition, Military Armaments, Explosive Devices, and Firearm Parts Human Remains and Body Parts Human Trafficking Child Exploitation Repeat / automated bids |
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