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Prohibited Customers & Activities Policy

Last Updated: July 2025
Table of Content
🚫 Prohibited Customers🚫 Prohibited Jurisdictions:⚠️ Prohibited Activities🔄 Updates

Spritz Finance is committed to compliance with all applicable anti-money-laundering (AML), counter-terrorist-financing (CTF), and sanctions regulations. To protect our network, our partners, and the financial system, we maintain a list of Prohibited Customers and Prohibited Activities. By using Spritz services (including API integrations), you agree not to onboard, process transactions for, or otherwise enable any customer or activity that falls within these categories.

🚫 Prohibited Customers

  • Appears on any sanctions or restricted party list maintained by OFAC, U.S. Department of Commerce, UN, EU, or UK.
  • A person named on Specially Designated Nationals (SDN list) and Blocked Persons.
  • Acting as an undisclosed third party or nominee.
  • Shell banks or otherwise prohibited under U.S. or international AML laws.
  • Acting on behalf of another individual or person or pretending to be someone else.
  • Anyone involved in elicit activities or in facilitation of:
    • Money laundering or terrorist financing
    • Human trafficking or smuggling
    • Drug trafficking or organized crime
    • Illegal gambling or unlicensed gaming operations
    • Proliferation of weapons or military-grade equipment without license
    • Environmental or wildlife trafficking crimes
  • Transacting in the dark web and supporting child abuse materials.A person or a company with unverifiable identity and with no physical address.
  • Customers unwilling to undergo Enhanced Due Diligence (EDD) when required.
  • Entities or individuals who refuse to comply with the AML/CTF compliance requirements.
  • Customers attempting to circumvent onboarding, reporting, or monitoring requirements.
  • Unexplained source of wealth and source of funds.
  • Customers dealing with privacy coins.
  • Customers with negative media linking them to fraud, corruption, sanctions evasion, or other financial crimes.
  • Entities or individuals under investigation or indictment for major financial crimes, even if not yet convicted.
  • Sellers or exporters of counterfeit goods, fake/falsified documents, or pirated content.
  • Non-profit organizations or charities that lack verifiable legitimacy or financial transparency.
  • NPOs located in or sending funds to conflict zones or terrorist financing hotspots.
  • FATF blacklisted countries, high-risk offshore secrecy havens, U.S.-prohibited or embargoed jurisdictions or anyone located in, organized under the laws of, or ordinarily resident in the  Prohibited Jurisdictions listed below:

🚫Prohibited Jurisdictions:

  • Afghanistan
  • Albania
  • Belarus
  • Bosnia & Herzegovina
  • Burma (Myanmar)
  • Central African Republic
  • China (selected sanctioned entities/sectors)
  • Cuba
  • Crimea/Donetsk/Luhansk Regions of Ukraine
  • Democratic Republic of Congo
  • Eritrea
  • Ethiopia
  • Guinea
  • Haiti
  • Iran
  • Iraq
  • Kosovo
  • Lebanon
  • Liberia
  • Libya
  • Mali
  • Moldova
  • Montenegro
  • North Korea
  • Nicaragua
  • Russia
  • Serbia
  • Somalia
  • South Sudan
  • Sudan
  • Syria
  • Ukraine (occupied territories)
  • Venezuela
  • Vietnam
  • Yemen
  • Zimbabwe

⚠️ Prohibited Activities

  • Unlicensed money services businesses, unregistered money transmission, or digital asset exchanges.
  • Undisclosed third‑party payment processing, check cashing, bail bonds, collections agencies.
  • White‑label ATM services.
  • Sale or distribution of controlled substances without proper licensing.
  • Marijuana businesses (including ancillary services) where not federally legal.
  • Pharmaceuticals, tobacco or nicotine products without licensing.
  • Precious metals/gems sales without appropriate controls.
  • Firearms, ammunition, explosives, or related accessories.
  • Adult content or escort services.
  • Unlawful gambling, betting, sweepstakes, or lotteries.
  • Ponzi schemes, pyramid schemes, or deceptive marketing.
  • Counterfeit or 'gray market' goods.
  • Products or services that infringe on intellectual property rights.
  • Transactions benefiting individuals, entities, or countries subject to economic sanctions.
  • Transactions intended to conceal the origin of funds or otherwise circumvent AML laws.
  • Activities promoting violence, hate, harassment, or abuse.
  • Transacting directly or indirectly with terrorist organizations or funding/supporting terrorism.
  • Using false or stolen identities to open an account.

🔄 Updates

This policy may be updated from time to time based on regulatory changes, partner requirements, or internal risk assessments. The current version will always be available at https://spritz.finance/legal/prohibited