Restricted Categories

1. Sanctions

HEVN does not support any customer, beneficial owner, director, authorized user, counterparty, transaction, or business activity that is prohibited under applicable sanctions laws or the requirements of an Account Provider.

This includes:

• persons or entities designated on applicable sanctions lists;
• entities owned or controlled by sanctioned persons, including where sanctions rules aggregate ownership;
• transactions involving comprehensively sanctioned countries or territories;
• attempts to conceal a sanctioned party, jurisdiction, ownership interest, origin, destination, or economic purpose; and
• activity intended to evade or circumvent sanctions, export controls, or other applicable restrictions.

Sanctions screening may be performed during onboarding and throughout the relationship. A potential or confirmed sanctions match may result in a request for information, rejection, suspension, return of funds, account closure, or another action required by law or an Account Provider.

2. Politically Exposed Persons (PEPs)

PEP status is not automatically prohibited. However, an application involving a politically exposed person, a family member, or a close associate is subject to enhanced due diligence and approval by the applicable Account Provider.

You must disclose known PEP status for any beneficial owner, director, control person, authorized user, or other relevant person. HEVN or an Account Provider may request additional information about source of wealth, source of funds, public function, business relationships, and transaction purpose.

Approval is not guaranteed. Services may be unavailable where the required review cannot be completed or the applicable Account Provider does not accept the risk.

3. Country Restrictions

HEVN does not currently support onboarding for businesses incorporated in, or individuals residing in, the following countries:

• Belarus
• Cuba
• Iran
• Myanmar
• North Korea
• Russia
• Syria

Country eligibility also depends on beneficial ownership, directors, authorized users, countries of operation, counterparties, payment destinations, currencies, and the selected Account Provider or payment rail. A country not listed above is not guaranteed to be supported.

Additional jurisdictions, regions, or corridors may be unavailable or subject to enhanced review because of sanctions, conflict, regulatory requirements, financial-crime risk, or Account Provider policy. Country restrictions may change without notice where required by law or a regulated partner.

4. Industries

The following business categories are generally not supported:

• unlicensed money transmission, remittance, payment processing, foreign-exchange dealing, or other regulated financial activity;
• accepting deposits, holding customer funds, or moving money on behalf of unaffiliated third parties without required authorization;
• unlicensed gambling or betting;
• adult content or adult services;
• ammunition, firearms, weapons, explosives, military equipment, or related munitions, including their manufacture, sale, distribution, financing, or facilitation;
• cannabis and controlled-substance businesses;
• tobacco, nicotine, or e-cigarette businesses;
• shell banks, bearer-share structures, or businesses designed to conceal ownership or control;
• counterfeit goods or goods that infringe intellectual-property rights; and
• multi-level marketing, pyramid schemes, or get-rich-quick schemes.

The following categories require enhanced review and may require prior approval from the applicable Account Provider:

• online marketplaces or platforms that receive or route funds for third parties; and
• dealers in high-value goods or other businesses with elevated fraud, chargeback, money-laundering, or reputational risk.

Approval of a company does not mean that every product, currency, country, counterparty, or payment rail is available to that company.

5. Regulated Industries

Regulated industries are not automatically prohibited, but they require enhanced review and prior approval from the applicable Account Provider. This includes:

• licensed financial institutions and regulated financial-services businesses;
• money-service businesses and licensed remittance providers;
• digital-asset services, including custody, exchange, transmission, brokerage, or other crypto-asset service-provider activity;
• FX, CFD, securities, commodities, or investment brokerage; and
• other businesses that require a financial, payment, gambling, lending, investment, digital-asset, or similar regulatory license.

The applicant must hold every license, registration, and authorization required for its activity and jurisdictions. HEVN or an Account Provider may request regulatory-register evidence, compliance policies, audited financial statements, source-of-funds and source-of-wealth information, transaction-flow documentation, and additional due-diligence materials.

Approval is product- and provider-specific and is not guaranteed. A regulated business may be approved only for payments involving its own operating funds and still be prohibited from handling customer money through HEVN.

6. Payment Processors

HEVN supports only first-party payments directly related to the customer's own operating activity. A company may use HEVN to receive its own business revenue and pay its own suppliers, contractors, employees, taxes, and other legitimate operating expenses, subject to account and payment-rail rules.

HEVN does not support using an Account to:

• receive, hold, pool, transmit, convert, or settle funds on behalf of customers or other unaffiliated third parties;
• provide payment processing, money transmission, remittance, merchant acquiring, collection-account, escrow, or settlement services;
• operate a marketplace, platform, agent, nominee, or intermediary flow in which the company is not the true commercial payer or payee; or
• route third-party funds through the Account while presenting them as the company's own operating funds.

A company whose business includes payment technology or financial software may be considered only where its HEVN activity is limited to its own first-party operating payments and it does not use HEVN to process or safeguard customer funds.

7. Illegal Activities

HEVN does not support any activity that is illegal, fraudulent, deceptive, harmful, or intended to bypass legal, regulatory, Account Provider, or payment-network controls. Prohibited activity includes:

• money laundering, terrorist financing, or proliferation financing;
• fraud, scams, identity theft, impersonation, or submission of false or misleading information;
• bribery, corruption, sanctions evasion, or concealment of beneficial ownership;
• trafficking, exploitation, cybercrime, ransomware, or trade in stolen data or property;
• sale or distribution of illegal drugs, counterfeit goods, or unlawfully obtained goods; and
• structuring, pass-through activity, or use of third parties to disguise the source, destination, owner, or purpose of funds.

This list is not exhaustive. HEVN and its Account Providers may reject or restrict any activity prohibited by applicable law, payment-network rules, account-specific terms, or partner policy.

8. C2B Payments (Restricted, Not Prohibited)

Consumer-to-business (C2B) payments are restricted, not categorically prohibited. An incoming payment from an individual to a company may be supported only where the relevant account, currency, payment rail, corridor, and Account Provider permit it.

A supported C2B payment must:

• pay for a genuine product or service supplied by the receiving company;
• identify the individual customer and the commercial purpose of the payment;
• match an invoice, order, contract, or other supporting record when requested; and
• comply with applicable consumer-protection, refund, sanctions, fraud-prevention, and payment-network requirements.

C2B payments may not be used to operate an unlicensed payment service, collect or pool funds for third parties, accept customer deposits, provide money transmission, or conceal the true sender or beneficiary.

HEVN or an Account Provider may request supporting documents, place limits on C2B activity, restrict particular senders or corridors, or reject or return a payment. Contact HEVN before relying on C2B collections for your business model.