Prohibited Activities List

You may not use the Services, including the SpotPay Platform, SpotPay Wallet, SpotPay Card, or any other SpotPay products or services, to engage in, facilitate, support, fund, enable, or benefit from any of the activities described below. These restrictions apply to all users, including individuals, businesses, merchants, organizations, and any person acting on behalf of another person or entity.

The examples listed below are representative but not exhaustive. SpotPay reserves the right to modify or update this list at any time by posting a revised version on its website. Any revised version will become effective immediately upon posting.

If SpotPay determines, in its sole discretion, that you engage or have engaged in activities that are illegal, violate applicable laws or regulations, may harm others, may expose SpotPay or its partners to legal, regulatory, financial, reputational, operational, compliance, or fraud risk, or otherwise violate these Terms, SpotPay may deny, restrict, suspend, terminate, or condition your access to the Services without prior notice.

Category 1: Regulated or Illegal Activities

• Sale, distribution, manufacture, possession, or facilitation of controlled substances in violation of applicable law.
• Sale, distribution, manufacture, possession, or facilitation of firearms, ammunition, weapon components, explosives, or other regulated weapons where prohibited by applicable law.
• Production, sale, distribution, possession, or facilitation of illegal materials, including child sexual abuse material or other unlawful content.
• Gambling, betting, lotteries, sweepstakes, games of chance, sports wagering, fantasy sports, or similar activities unless expressly approved by SpotPay and permitted by applicable law.
• Prostitution, escort services, human trafficking, or any activity involving sexual exploitation.
• Sale, distribution, or facilitation of counterfeit, stolen, pirated, or gray market goods.
• Political fundraising, political contributions, or political campaign activities where prohibited by applicable law or not expressly approved by SpotPay.
• Pawn shops, unlicensed auction platforms, unlicensed financial services, or similar regulated activities.
• Ponzi schemes, pyramid schemes, investment fraud, market manipulation, deceptive business practices, or any activity intended to defraud or mislead others.
• Any activity that violates applicable local, national, or international laws or regulations.

Category 2: Intellectual Property Violations

• Sale, distribution, reproduction, or transmission of music, movies, software, digital content, or other licensed materials without appropriate authorization.
• Counterfeit goods, pirated products, or illegally imported or exported products.
• Unauthorized sale of branded, trademarked, patented, copyrighted, or designer products.
• Any activity that infringes or facilitates infringement of trademarks, patents, copyrights, trade secrets, privacy rights, publicity rights, or other proprietary rights of any third party.

Category 3: Violent, Harmful, or Hateful Activities

• Promoting, supporting, encouraging, glorifying, financing, or facilitating violence, terrorism, criminal activity, or physical harm.
• Promoting, supporting, encouraging, or facilitating hate, discrimination, harassment, or violence against any individual or group based on race, ethnicity, religion, national origin, citizenship, immigration status, disability, sex, gender, gender identity, sexual orientation, age, veteran status, or any other legally protected characteristic.
• Organizations, groups, or individuals associated with terrorism, violent extremism, organized crime, or other unlawful activities.

Category 4: Misuse of SpotPay Products and Services

• Providing false, misleading, manipulated, inaccurate, incomplete, or fraudulent information regarding your identity, activities, source of funds, beneficial ownership, or any information requested by SpotPay.
• Using the Services on behalf of another person or entity without disclosure to and approval by SpotPay.
• Circumventing account limits, verification requirements, sanctions screening, fraud controls, geographic restrictions, transaction monitoring controls, or other compliance measures.
• Using the Services to conceal the source, destination, ownership, beneficiary, or purpose of funds.
• Using SpotPay intellectual property without authorization.
• Using the SpotPay name, trademarks, service marks, branding, or logos in a manner that implies a false endorsement, affiliation, sponsorship, or partnership with SpotPay.
• Creating multiple accounts or using nominees, agents, intermediaries, shell entities, or other structures to circumvent SpotPay policies or restrictions.

Category 5: Sanctions, Export Controls, and Restricted Jurisdictions

You may not use the Services directly or indirectly:

• In violation of any applicable sanctions, embargoes, export controls, trade restrictions, anti-boycott laws, or similar laws and regulations administered or enforced by the United States or any other applicable governmental authority.
• On behalf of, at the direction of, or for the benefit of any person, entity, organization, government, vessel, aircraft, or other party that is subject to sanctions or other restrictions under applicable law.
• To purchase, sell, transfer, receive, fund, facilitate, broker, arrange, or otherwise enable any transaction involving a person, entity, organization, government, vessel, aircraft, or other party that is subject to sanctions or other restrictions under applicable law.
• To purchase, sell, transfer, receive, fund, facilitate, broker, arrange, or otherwise enable any goods or services that are prohibited by applicable sanctions, export controls, trade restrictions, or similar laws.
• To purchase, sell, transfer, receive, fund, facilitate, broker, arrange, or otherwise enable the purchase or provision of goods or services in, from, through, or for the benefit of any country, territory, region, person, or entity subject to comprehensive sanctions, embargoes, or similar restrictions under applicable law.
• To enable another person or entity to engage in conduct that would be prohibited if conducted directly by you.
• To evade, avoid, circumvent, conceal, or attempt to circumvent sanctions, embargoes, export controls, trade restrictions, or other legal restrictions.
• To disguise the origin, destination, ownership, beneficiary, purpose, or nature of any transaction involving a restricted person, entity, jurisdiction, or activity.
• In connection with any transaction that SpotPay reasonably believes may expose SpotPay, its banking partners, card network partners, service providers, vendors, or other partners to sanctions-related, regulatory, legal, financial, or reputational risk.

SpotPay may prohibit, block, suspend, reverse, reject, investigate, or report any transaction that it believes may violate applicable sanctions, export controls, trade restrictions, anti-money laundering requirements, card network rules, banking partner requirements, internal compliance policies, or other legal or regulatory obligations.

The countries, territories, regions, persons, entities, industries, and activities subject to sanctions or other restrictions may change from time to time. SpotPay reserves the right to apply restrictions based on current applicable laws, regulations, governmental guidance, card network requirements, banking partner requirements, and internal compliance policies, whether or not a specific jurisdiction, person, entity, product, or service is expressly identified in these Terms.

Category 6: Money Laundering, Fraud, and Financial Crime

• Money laundering or attempts to disguise the source, ownership, nature, or destination of funds.
• Terrorist financing or support of sanctioned organizations.
• Fraud, identity theft, account takeover, synthetic identity activity, or impersonation.
• Check fraud, payment fraud, card fraud, chargeback abuse, refund abuse, friendly fraud, or transaction laundering.
• Structuring transactions to avoid reporting thresholds, compliance controls, transaction monitoring, or legal requirements.
• Use of stolen payment credentials, stolen identities, or unauthorized financial accounts.
• Any activity intended to conceal beneficial ownership, evade law enforcement, or facilitate criminal conduct.
• Fraudulent chargebacks, false disputes, abuse of consumer protection mechanisms, or attempts to obtain goods, services, or funds through deception.
• Transactions involving proceeds of crime or funds derived from illegal activity.

Category 7: Virtual Assets and Digital Asset Abuse

• Use of cryptocurrency mixers, tumblers, anonymization services, chain-hopping services, obfuscation protocols, or similar services designed to conceal transaction history, ownership, source of funds, or destination of funds.
• Transactions involving wallet addresses, smart contracts, protocols, applications, or digital assets that SpotPay reasonably believes are associated with sanctions evasion, money laundering, terrorist financing, ransomware, fraud, theft, hacking, darknet marketplaces, or other unlawful activity.
• Transactions involving stolen digital assets, hacked funds, exploit proceeds, ransomware proceeds, or other illicit digital assets.
• Use of the Services to conceal the beneficial ownership of digital assets or otherwise evade compliance requirements.

Restricted Activities

Certain activities, users, products, services, or transactions may be subject to additional review, enhanced due diligence, transaction limits, monitoring, temporary restrictions, or denial of service at SpotPay's discretion.

Examples include:

• Money transmission or financial services activities conducted on behalf of third parties.
• Cryptocurrency or digital asset businesses.
• Charitable fundraising or donation campaigns.
• Gambling activities that may be lawful in certain jurisdictions.
• Transactions involving jurisdictions, persons, entities, products, or services subject to sanctions, export controls, or other legal restrictions.
• Transactions that SpotPay reasonably determines present elevated legal, regulatory, compliance, fraud, financial, operational, or reputational risk.

SpotPay may request additional information or documentation before permitting or continuing such activity and may impose additional restrictions or deny access to the Services at its discretion.