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, entities, vessels, aircraft, or other parties identified on (i) the U.S. Department of the Treasury, Office of Foreign Assets Control ("OFAC") Specially Designated Nationals and Blocked Persons List (the "SDN List") or any other sanctions list administered by OFAC, including OFAC's consolidated non-SDN lists; (ii) the Consolidated Canadian Autonomous Sanctions List or otherwise designated under applicable Canadian sanctions legislation; or (iii) the consolidated list of persons, groups, and entities subject to European Union financial sanctions;
• Entities owned or controlled by sanctioned persons, including where sanctions rules aggregate ownership;
• Activity intended to evade or circumvent sanctions, export controls, or other applicable restrictions.

Country-based prohibitions are addressed in Country 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. Country Restrictions

For purposes of this section, Prohibited Jurisdictions means:

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

By applying for, accessing, or using any HEVN service, each applicant and customer represents, warrants, and undertakes on a continuing basis that:

• It is not incorporated, registered, headquartered, resident, or principally operating in a Prohibited Jurisdiction;
• It does not conduct business in, maintain material commercial or financial relationships with, process payments involving, or transact or intend to transact with any person or entity located, resident, incorporated, registered, or operating in a Prohibited Jurisdiction;
• It is not directly or indirectly owned or controlled by a government or public authority of a Prohibited Jurisdiction, or by any person or entity located, resident, incorporated, registered, or operating in a Prohibited Jurisdiction; and
• It is not acting, directly or indirectly, as an agent, nominee, intermediary, or representative of, or for the benefit of, a Prohibited Jurisdiction or any such person or entity.

These restrictions apply whether the relevant ownership, control, relationship, activity, or transaction is direct or indirect, including where it is conducted through an affiliate, intermediary, nominee, agent, counterparty, payment chain, or other arrangement.

Notwithstanding the foregoing, nationality alone does not automatically render an individual ineligible. A national of a Prohibited Jurisdiction may be considered only if the individual lawfully resides in and holds valid residence status in a jurisdiction that is neither listed above nor subject to applicable comprehensive sanctions.

Any such application is subject to enhanced due diligence (EDD) and prior approval by HEVN and the applicable Account Provider. The applicant must fully disclose and explain all current and historical ties to each country of nationality or origin, including residential, family, business, employment, property, banking, and financial connections. HEVN or an Account Provider may require documentary evidence concerning immigration and residence status, tax residence, source of wealth, source of funds, counterparties, expected transactions, and the purpose and nature of any continuing ties. Approval is not guaranteed and may be withheld in HEVN's or the applicable Account Provider's discretion.

The applicant and customer must promptly notify HEVN of any change that could make a representation in this section inaccurate or incomplete. Any failure to disclose relevant ties, ownership, control, relationships, or transaction exposure, or any attempt to conceal or misrepresent them, constitutes a material breach and may result in rejection, restriction, suspension, return of funds, or termination of services without prior notice where permitted or required by law or an Account Provider.

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. Jurisdictions and corridors not listed above may still be unavailable or require enhanced review, and eligibility may change where required by law or an Account Provider.

3. Prohibited Industries

The following business categories are generally not supported:

• Unlicensed financial services, including money transmission, remittance, payment processing, foreign-exchange dealing, accepting deposits, or holding customer funds;
• Cryptocurrency ATM businesses, including the deployment, operation, management, or facilitation of machines used to buy, sell, or exchange digital assets;
• Ammunition, firearms, weapons, explosives, military equipment, or related munitions, including their manufacture, sale, distribution, financing, or facilitation;
• Cannabis and cannabis-related businesses, whether legal or illegal under local law, including cultivation, production, processing, distribution, sale, marketing, cannabis-derived products, THC products, cannabis-derived CBD products, extracts, and related paraphernalia;
• Jewelry, silverware, precious-stone, diamond, gemstone, or similar high-value-goods retailers, wholesalers, manufacturers, or processors;
• Tobacco, nicotine, or e-cigarette businesses;
• Shell banks, bearer-share structures, or businesses designed to conceal ownership or control;
• Multi-level marketing, pyramid schemes, or get-rich-quick schemes; and
• Any other business that HEVN or an applicable Account Provider determines presents unacceptable financial-crime, sanctions, fraud, chargeback, regulatory, legal, operational, or reputational risk.

4. Illegal Activities

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

• Unlawful activity: using the Services in a manner that violates, facilitates the violation of, or helps another person violate any applicable law, regulation, court order, or Account Provider requirement. This includes money laundering, terrorist or proliferation financing, bribery, corruption, trafficking, exploitation, illegal drugs, unlawful content or information, transactions involving proceeds of crime, and trade in stolen or unlawfully obtained data, goods, or property.
• Abusive or harmful activity: disrupting, damaging, impairing, or placing an unreasonable burden on the Platform, Services, Account Providers, payment networks, or another person's systems or accounts. This includes introducing malware or malicious code; cybercrime or ransomware; probing, scanning, or testing vulnerabilities without authorization; attempting to gain unauthorized access; using another person's Account or credentials without permission; or selling, assigning, transferring, sublicensing, or sharing Account access without HEVN's prior written approval.
• Fraud or misrepresentation: any act or omission intended or reasonably likely to deceive or mislead HEVN, an Account Provider, a customer, a counterparty, or another person. This includes scams, identity theft, impersonation, forged or manipulated documents, misrepresenting affiliation or authority, and providing false, inaccurate, incomplete, or misleading information during onboarding or use of the Services.
• Unlawful or unlicensed gambling: conducting, participating in, processing payments for, or supporting gambling that is prohibited by applicable law or not authorized by the required regulator. This includes lotteries, sports betting or odds-making, fantasy sports with cash prizes, internet gaming, contests, sweepstakes, games of chance, and substantially similar activity.
• Intellectual-property and proprietary-rights violations: infringing, misappropriating, or facilitating the infringement or misappropriation of another person's copyrights, trademarks, patents, trade secrets, rights of publicity or privacy, or other intellectual-property or proprietary rights, including the sale or distribution of counterfeit goods.
• Concealment and circumvention: structuring transactions, using pass-through activity or third parties, or taking any other action to disguise or misrepresent beneficial ownership, source of funds, source of wealth, sender, beneficiary, destination, commercial purpose, or other material information.

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.

5. Politically Exposed Persons (PEPs)

Restricted categories require enhanced due diligence (EDD) and prior approval. The approved scope may vary by product, account, currency, payment rail, corridor, counterparty, or transaction type. HEVN or an Account Provider may limit use of the Services to first-party payments, where the customer is the true commercial payer or payee and does not handle funds on behalf of unaffiliated third parties.

PEP status is not automatically prohibited. An applicant must disclose known PEP status involving any beneficial owner, director, control person, authorized user, family member, close associate, or other relevant person.

HEVN or an Account Provider may request information about source of wealth, source of funds, public function, business relationships, and transaction purpose. Services are unavailable where the required review cannot be completed or the risk is not accepted.

6. Regulated Industries

Regulated industries may be considered only where the applicant holds every license, registration, and authorization required for its activity and jurisdictions. 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.

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.

Other Restricted Industries

Other restricted categories include:

• Online marketplaces or platforms that receive or route funds for third parties; and
• Dealers in high-value goods not expressly prohibited above, or other businesses with elevated fraud, chargeback, money-laundering, or reputational risk.

7. C2B Payments

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 must represent the receiving company's own sales. They do not permit payment processing, customer deposits, collections for third parties, or concealment of the true sender or beneficiary.

Supporting documents may be required, and individual payments may be limited, rejected, or returned. Contact HEVN before relying on C2B collections for your business model.