1. Prohibited Activity
Sanctions evasion — transactions involving OFAC, EU, UK, UN, or Canadian sanctions targets.
Money laundering — placement, layering, or integration of proceeds of crime.
Fraud — identity theft, account takeover, unauthorized transactions.
Market manipulation: pump-and-dump schemes, fake-volume trading, structured deposits.
Illicit goods + services: narcotics, arms, child sexual abuse material, terror financing.
2. Restricted Activity
High-risk merchant categories (gambling, adult content, payday lending) — case-by-case approval required.
Crypto on/off-ramp: permitted on the regulated stablecoin rail under Travel-Rule compliance.
Cross-border transfers > $10K: auto-flagged for AML check per FINTRAC + FinCEN.
3. Enforcement
Suspicious activity is reported to FINTRAC + the appropriate FIU per local jurisdiction.
Accounts in breach of this policy may be frozen pending check and closed for cause.
