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Acceptable Use Policy

Last updated December 1, 2022

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Sila Inc. (together with its subsidiaries and affiliates, “Sila”), is a financial technology service provider operating as an agent of its one or more financial depository institution partners to facilitate their provision of banking and payments services (altogether, the “Services”) to Sila customers (each, a “customer”) and their platform application users (or “end users”). As an agent of a financial depository institution, Sila will perform certain approved functions on its behalf, including customer screening, onboarding, due diligence; provision of technology infrastructure and customer support; and other functions necessary to support its provision of the Services (together, the “Functions”). 

Every Sila customer (and each end user of the customer’s platform application and the Services) is strictly bound by this Acceptable Use Policy (this “Policy”). All customers and end users of the Services are independently responsible for complying with this Policy.

This Policy is incorporated into and made part of

  • the Sila Terms of Service;
  • each customer’s Master Services Agreement with Sila; and
  • each customer’s terms or conditions applicable against an end user of the Services upon reference in those terms or conditions.

This Policy may change periodically without notice, so customers and end users should review this Policy each time they use the Services. When this Policy is changed, the date of the latest revision will appear at the top of the page.

Companies that engage in or seek to support certain business activities or international transactions through use of the Services are either ineligible for the Services or subject to a high level of scrutiny by Sila and its principal financial institution. Sila enforces this Policy as part of its Functions to help support compliance with applicable law, regulations, partner requirements, payment system rules, and industry best practices.

This Policy is underpinned by four pillars, each an independent policy requirement:

  1. Prohibited Business Use
  2. Business Use Requiring Enhanced Review
  3. Prohibited Jurisdictions
  4. Jurisdictions Requiring Enhanced Review

IMPORTANT NOTICE: Sila customers must read, understand, and comply with each independent pillar of this Policy as a condition of initial and ongoing access to the Services. A customer’s violation of any pillar of this Policy constitutes a material breach of the Sila Master Services Agreement. An end user’s violation of this Policy constitutes a material violation of Sila’s Terms of Service and may result in expulsion from the Services and other legal action.


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First Pillar:

Prohibited Business Use

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No business or other entity is eligible to use the Services, either as a Sila customer or end user, if it assumes any of the following legally recognized forms:

  • an entity that is formed in a foreign jurisdiction of which its beneficial owners are neither residents nor citizens;
  • a business association that (i) is structured without active business operations or significant assets, or (ii) has any subsidiaries without active business operations or significant assets;
  • a business association formed under the name of any federally recognized indigenous American tribe pursuant to the rights and privileges afforded to that tribe under the Indian Reorganization Act, 25 U.S.C. § 5112 et. seq.; or
  • an entity whose bylaws or other chartering document permit the issuance of equity securities that are wholly owned by whoever bears the stock certificate.

Sila customers and end users are also strictly prohibited from using the Services to support any of the products, services, or methods of selling categorized below (each, a “Prohibited Use”).

If the nature of a customer’s platform application offers the potential for any end user of the Services to engage in any Prohibited Use, then the customer must not only incorporate this Policy into its end user-facing terms or conditions, but expressly prohibit every relevant Prohibited Use in those terms or conditions, in writing.

The description of each Prohibited Use below is simplified to offer guidance on what one or more activities are prohibited. The descriptions should be construed broadly; they are neither intended to establish legal or regulatory definitions of these terms nor guide you in any way as to the application of any law or rule. These descriptions should not be considered legal, regulatory, or compliance advice by any means. The word “including” as used in any description below should not be construed with limited scope and should be read as if immediately followed by the words “but not limited to.”

Sila and its partners prohibit these activities because they are either (a) highly susceptible to fraud and high dispute and chargeback rates; or (b) illegal or only legal in a limited number of jurisdictions or when complying with some specific set of formidable laws or rules. Sila customers are responsible for enforcing these prohibitions on their end users.

Prohibited Use Description
Adult Entertainment Payment for the support of or access to adult entertainment or pornography, either online or at a physical location, and regardless of whether or how monetized.
Aircraft Sales Purchase, sale, or exchange of any kind of aircraft or aircraft part, excluding any drone or other unmanned aerial vehicle (UAV).
Cannabis Product Sales Purchase, sale, distribution, or exchange of any kind to effect the acquisition of a cannabis product of any kind, including CBD oil but excluding any hemp product.
Card Network-Prohibited Activities Any transaction type prohibited by any card network, including transactions for any business that sets requirements for minimum or maximum transaction amounts.
Cash-Based MSB Activities Operations of a licensed or unlicensed money transmitter or check casher or its merchants or agents that support cash payments.
Cashless ATM Payments PIN-entry debit card payments at a merchant terminal device that processes payments only in incremental values, resulting in a cash disbursement to payers for the difference between the incremental value and the value owed to merchants.
Chat and Dating Services Monetization of any business or social media platform that facilitates interpersonal connections among clients or users seeking romantic or sexual partners.
Currency Exchange Exchange of one sovereign currency for another sovereign currency, whether or not licensed, either physically or online, either domestically or cross border, including where any digital asset may be used to intermediate the conversion.
Escort Services Sex trafficking or the marketing, sale, or facilitation of commercial sex acts, “companionship,” or other niche personal services, including the services of any type of “encounter” group or club.
Firearm and Ammunition Sales Manufacture, sale, or distribution of any firearm, firearm part, ballistics device, or ammunition of any kind, including any schematics or blueprints that can be used to independently manufacture firearms, whether with use of a 3D printer or otherwise.
Fireworks or Explosives Sales Manufacture, sale, or distribution of any firework or other form of highly regulated explosive.
“Get-Rich-Quick” Schemes The offer of a high rate of return on an initial investment without disclosure of how funds are invested or what risks are involved.
Illegal Services or Product Sales Marketing, sale, distribution, or exchange of products or services of any kind deemed illegal by any level of government.
Marijuana or Illicit Drug Sales Purchase, sale, distribution, or exchange of any kind to effect the acquisition of marijuana or any other controlled substance prohibited under the U.S. Department of Justice’s Schedules of Controlled Substances, 21 C.F.R. pt. 1308.
Massage Services Marketing, sale, or facilitation of any massage or similar personal care services unless associated with a licensed spa or chiropractic care office.
Multilevel Sales and Marketing Sales supported by commission-based chain referrals or similar franchises (also known as “pyramid schemes” or “franchise fraud”).
Nested Payments or Money Transmission The resale or repackaging of the Services or the services of any money services business for use by any person or business seeking to facilitate transactions for its own end users.
Online Tobacco Sales Online marketing, sale, or distribution of tobacco products to consumers.
On-Site or Unlicensed Gambling Includes each of the following:
  • On-Site Gambling or Wagering: Placement of any wager or payout of any winnings in support of the operations of any land-based casino, on-track or off-track betting site, or other betting house.
  • Unlicensed Gambling Games or Games of Chance: Direct placement of a wager or the marketing, purchase, sale, or exchange of any credit used to place a wager on any contest that has any clear element of a game of chance, including sports betting, track betting, online slots, poker, etc., whether live or virtual, but that is not sponsored by a state or local government agency or facilitated by a business specifically licensed under applicable state or local law.
Payday Lending Offering or repaying on any loan product or extension of credit covered under the U.S. Consumer Financial Protection Bureau’s Payday Lending Rules, 12 C.F.R. pt. 1041.
Pharmaceutical Sales Marketing, sale, or distribution of any kind of prescription medication or over-the-counter pharmaceutical regulated under the U.S. Department of Justice’s Schedules of Controlled Substances, 21 C.F.R. pt. 1308.
“Pseudo” Product Sales Purchase, sale, or distribution of any product that uses deceptive labeling or imitation practices or false names or endorsements.
Rotating Credit and Savings Pooling funds among participants to facilitate unregulated investing, lending, or savings, including on a round-robin basis or otherwise.
Tattoo Services Purchase, sale, or provision of tattoos as a product or service.
Tax Anticipation Services Marketing, offer, purchase, sale, or underwriting of any kind of tax refund anticipation loan.
Unfair, Predatory, or Deceptive Practices Marketing, purchase, sale, or distribution of products or services of any kind that support fraud or engage in any unfair, deceptive, or abusive act as defined by the U.S. Consumer Financial Protection Bureau under 12 C.F.R. pt. 1041.

 


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Second Pillar:

Business Use Requiring Enhanced Review

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Sila customers are prohibited from using the Services or allowing end users to use the Services to support any of the products, services, or methods of selling categorized below (each, a “Restricted Use”) except with Sila’s express prior written approval.

Before granting approval to a customer to engage in or support any Restricted Use, Sila will request, collect, and review specific documentation from a customer above and beyond what Sila and its partners require for standard customer due diligence. The customer’s supporting documentation must bolster Sila’s finding that the customer is suitably knowledgeable about and compliant with all law and regulation that may be independently applicable to its business and related activities. The customer must demonstrate it has adequate risk-based controls necessary to ensure ongoing compliance with its independent regulatory requirements and best practices within its one or more industries.

If the nature of a customer’s platform application offers the potential for any end user of the Services to engage in any Restricted Use not explicitly approved by Sila in writing, then the customer must, not only incorporate this Policy into its end user-facing terms or conditions, but, expressly prohibit every relevant Restricted Use in those terms or conditions, in writing.

The description of each Restricted Use below is simplified to offer guidance on what one or more activities are restricted. The descriptions should be construed broadly; they are not intended to provide you with legal or regulatory definitions of these terms. These descriptions should not be considered legal, regulatory, or compliance advice by any means. Any form of the word “include” (or “including”) contained in a description does not limit the description’s scope; it should be constructed as if immediately followed by the words “but not limited to.”

Sila and its partners prohibit these activities because they are either (a) highly susceptible to fraud and high dispute and chargeback rates; or (b) illegal or only legal in a limited number of jurisdictions or when complying with some specific set of formidable laws or rules. Sila customers are responsible for enforcing these prohibitions on their end users.

Restricted Use Description
"As Seen on TV" Product Sales Marketing, sale, or distribution of any product currently or previously advertised on television in “infomercials” for direct purchase by mail order or phone order.
Arcade Sales or Video Game Vending  Arcade or video game play sales, or the provision, servicing, or leasing of video or arcade game equipment.
Auction Sales Payment as part of any auction for the sale of property or services, either privately or to the general public.
Charitable and Nonprofit Payments Includes each of the following:
  • Political Fundraising or Financing: Payment supporting any kind of operations of or fundraising for any kind of political organization, including any civic league, political campaign or cause, candidate for public office, or political action committee.
  • Other Nonprofit Fundraising or Financing: Donation or financing of any nonprofit organization of any kind contributed by any person or entity of any kind.
  • Home-Based Charity Payments: Payment supporting any sales, operations, or fundraising of any nonprofit charitable organization operated primarily out of the home or homes of its principals.
Credit Card Scheme Operation of a card payment network that solicits memberships from financial institutions for card issuing.
Credit Repair and Debt Relief Includes each of the following:
  • Credit Repair: Offering credit score repair by reporting consumer repayments to credit bureaus.
  • Credit Restoration or Debt Relief: Marketing, purchase, or sale of any service designed to help consumers restore their credit score or seek debt relief by disputing reports with credit bureaus or negotiating with creditors to seek loan forgiveness, or to consider options inside or outside of bankruptcy.
Crowdfunding Includes each of the following:
  • Donation Crowdfunding: Fundraising by individuals, charities, or public or nonprofit organizations to raise funds from platform users as personal gifts or charitable contributions.
  • Retail Securities Crowdfunding: Fundraising by individuals, companies, or other associations or startups to raise funds for business ventures as Reg CF-exempt securities.
Cryptocurrency and Decentralized Platform Activities Includes each of the following:
  • Integration Partner-Only Activities: Purchasing, selling, exchanging, or custodying cryptocurrency solely through an approved Sila network integration partner, according to an approved funds flow, and where the customer is not performing any regulated functions.
  • Third-Party Service Provider Activities: Marketing, purchase, sale, exchange, custody, or use of any kind of transactional token (i.e., cryptocurrency, virtual currency, stablecoin, etc.) while acting as a vendor for an approved third-party service provider selected by the customer to properly perform regulated functions, including if it is used merely to support a decentralized application.
  • Customer Regulated Activities: Marketing, purchase, sale, custody, or use of any kind of digital token, including if it is used merely to support a decentralized application, where the customer is performing any directly regulated activities, as an MSB or otherwise; this includes any support or use of any of the following types of digital tokens: (a) transactional token: cryptocurrency, virtual currency, stablecoin, etc.; (b) decentralized application (dApp) tokens: platform token, utility token, governance token, social token, creator token, etc., and including any kind of non-fungible token (NFT), which typically uses either ERC-721 (1 of 1) or ERC-1155 (1 of many) tokens on the Ethereum network; or (c) security token: ICO token, digital security, etc.
Debt Collection Third-party collection or recovery of funds from a consumer or business debtor on behalf of any creditor or biller.
Digital Skill-Based Wagering or Licensed Gambling Includes each of the following:
  • Daily Fantasy Sports or Other Games of Skill: Direct placement of a wager for Daily Fantasy Sports (DFS) or for clear games of skill, such as in-person betting on a user’s own skilled performance like a race, chess match, golf game, etc.
  • Licensed Digital Gambling Games or Games of Chance: Direct placement of a wager or the marketing, purchase, sale, or exchange of any credit used to place a wager on any contest that has any clear element of a game of chance, including sports betting, track betting, online slots, poker, etc., whether live or virtual, and that is sponsored by a state or local government agency or facilitated by a business specifically licensed under applicable state or local law.
Direct Marketing Includes each of the following:
  • Direct Catalog Marketing: Marketing or sale of any retail product or service directly to consumers using primarily a type of catalog or brochure, printed or digital.
  • Direct Subscription Marketing: Marketing or sale of any retail product or service directly to consumers primarily based on a subscription or recurring payment of relatively low amounts or at high profit margins.
Door-to-Door Sales Marketing or sale of any subscription, brand, product, or service, or the collection of commercial information by canvassing homes or public areas.
Futures, Forwards, Options, or Swaps Markets Includes each of the following:
  • Exempt Futures Contracts: Provision of any futures contract exempt by the Commodity Exchange Act, its implementing regulations, or pursuant to no-action relief granted by the CFTC.
  • Other Derivatives Contracts: Purchase, sale, exchange, or provision of any derivative financial vehicle, including any forward, option, swap, or nonexempt futures contract.
Gig Economy Platform Activities Includes each of the following:
  • Gig Economy Marketplace: Consumer payments to independent contractors (or “gig” workers) in exchange listed services to be performed by contract or freelance based on unique consumer needs.
  • Gig Economy PayFac Platform: Consumer payments on a gig economy platform in exchange for a service, where the platform operator is acting as a payment facilitator.
Government Grant Acquisition Services Offer or provision of services to assist individuals or organizations with applying for or obtaining government monetary grants.
Government Services Provision of government services, either by a government-chartered entity, department, agency, or arm, or a profit or nonprofit business contracting with a government entity to perform services or carry out certain government functions.
Group Savings or Payments Includes each of the following:
  • Group Savings or Bill Splitting: Collection or pooling of funds of any group of individuals to save or spend collectively, or to pay or reimburse for shared expenses, such as splitting payment on any check, invoice, receipt, or bill.
  • Income Pooling: Collection or pooling of the funds of any group of income earners under a multilateral contract governing use of the funds by its participants upon satisfaction of a condition or set of conditions.
Insurance and Annuity Sales Includes each of the following:
  • Commercial Insurance Sales: Marketing, offer, purchase, or sale of any other type of commercial consumer or non-consumer insurance of any kind, including any liability insurance, auto insurance, renter’s insurance, loan guaranty, bond, corporate insurance, or independent home or product warranty of any kind.
  • Life Insurance and Annuity Sales: Marketing, offer, purchase, or sale of any type of life insurance, annuities, premium insurance bonds, or other insurance products that have a cash value to the holder or beneficiary.
International Payments Any transaction that supports or serves as any part of the transfer of value cross border between any U.S. state (including the District of Columbia) and any other jurisdiction, including any foreign country or U.S. territory or possession.
Legal or Contract Services Includes each of the following:
  • Legal Services: Any transaction that supports or serves as any part of the transfer of value to pay for or retain legal services of any kind.
  • Contract Services: Any transaction that supports or serves as any part of the transfer of value to satisfy a condition of any legally binding contract supplied by a platform application for execution among end users.
Lending Includes each of the following:
  • Business Lending, Trade Financing, or Merchant Cash Advance: Extension or sale of any merchant cash advance product of any kind, or the extension of credit or the marketing, offer, purchase, sale, or underwriting of any business-to-business or institutional enterprise lending of any kind, regardless of whether the lending product is collateralized, guaranteed, or otherwise.
  • Consumer or Small Business Lending: Extension of credit or the marketing, offer, purchase, sale, or underwriting of any other general consumer loan or small business, nonprofit, or community development loan of any kind, including any microfinancing, credit repair loans, or non-interest or nonprofit loans, regardless of whether the lending product is collateralized, guaranteed, or otherwise.
  • Short-Term Lending: Offering or repaying on any short-term loan product or extension of credit, including any short-term loans, loans in anticipation of a consumer paycheck or government-issued check, loans backed by a security interest in a vehicle title, and certain other high-cost borrowing products, but which is not not otherwise a covered loan under the U.S. Consumer Financial Protection Bureau’s Payday Lending Rule, 12 C.F.R. pt. 1041.
  • Pawn Shop Services: Marketing, issuance, provision, or underwriting of any kind of loan requiring delivery of possession of a borrower’s personal property as collateral for the loan.
  • Bail Bond Services: Provision of loans or bonds to any person who is charged with a crime for which she may be incarcerated for the purpose of posting bail with the court overseeing the charge.
Loan Servicing or Assistance Includes each of the following:
  • Loan Servicing: Collection of regular or recurring payments from any kind of borrower, either on behalf of a lender or creditor or to service a debt purchased from a lender or creditor.
  • Student Loan Assistance: Marketing, offer, or facilitation of any service offering to help a borrower to manage, repay, or seek forgiveness on a student loan.
Lottery Sales or Operations Includes each of the following:
  • Retail Lottery Vendor Sales: Purchase or sale of any ticket or token with payments or payouts of any public- or private-chartered lottery.
  • Government-Owned Lottery Operations: Purchase or sale of any ticket or token with payments directly to or from any state or government subdivision lottery commission.
Modeling, Talent, or Career Agency Services Payment for the service or commission of any platform application or self-employed or corporate talent agent or career coach providing networking or professional opportunities, career development or representation for any kind of industry, including in art, music, acting, modeling, content creation, or competitive sports.
Money Services Business (MSB) Activities Any transaction that supports or serves as any part of the transfer of value for the operations of a money services business (MSB), including any of the following:
  1. handling or holding client funds for electronic money transmission; foreign exchange or cross-border remittance;
  2. issuance or sale of any type of money order, traveler’s check, or other payment instrument;
  3. check cashing;
  4. sale or provision of any prepaid access to funds, such as a through use of a prepaid card or other prepaid program; or
  5. custody, issuance, administration, transfer, purchase, sale, or exchange of any type of digital token offering a substitute for real currency.
Nutraceutical, Vitamin, or Supplement Sales Marketing, sale, or distribution of vitamins, food additives, or dietary supplements regulated or exempt by the U.S. Food and Drug Administration pursuant to 21 C.F.R. pt.170.
On-Site Tobacco Sales Physical retail merchant sale any kind of tobacco or nicotine product, including any kind of paper or tobacco wrap, e-cigarette, or e-cigarette refill.
Payment Facilitator (PayFac) Services Acting as a “master merchant” or independent sales organization with a sponsor acquiring bank to intermediate the acceptance of cards on behalf of a portfolio of submerchants.
Precious Metals and Other High Value Sales Marketing, purchase, sale, exchange, or distribution of any kind of high-value tangible, including precious metals, gems, jewelry, watches, antiques, fine art, or rare collectibles.
Prediction Markets Placement of funds to enter into a kind of futures contract whose value is dependent on any certain event, outcome, or condition of any kind rooted in society or economics that supplies useful information to market participants or broader economies.
Private Sales of Goods Includes each of the following:
  • Bazaar or Open Marketplace Sales: Payment to any private vendor or individual for the purchase or sale of any kind of good at any physical, open-air location, including any kind of farmer’s market, street market, bazaar, “flea” market, garage sale, tag sale, or yard sale.
  • Secondhand Goods Marketplace Sales: Consumer payments to private sellers in exchange for secondhand goods on a digital marketplace or listing service, and for delivery either in person or by shipping via parcel service.
Raffles or Sweepstakes Includes each of the following:
  • Raffle Services: Payment for admission to any contest to obtain something of value by lot or chance, entry to which requires payment of a flat entry fee, where most funds raised are earmarked for a gift or charitable contribution.
  • Sweepstakes: Payment for admission to any contest to obtain something of value by lot or chance, entry to which comes with the payment of a fee or independent purchase, as long as the fee or purchase is not required for entry.
Real Estate Rental, Financing, Sales, or Management Includes each of the following:
  • Rental Property Management: Any transaction used to support the commercial finance, investment of exempt securities, or development of any kind of real estate or property management services.
  • Commercial Land Sales or Finance: Any transaction used to support the commercial finance, sale, investment, or development of any kind of real estate.
  • Private Real Estate Sales: Any transaction used to support any kind of private purchase or sale of real estate, including any retail residential real-estate sales.
  • Resort Land Development or Promotion: Any transaction used to support any real-estate development, promotion, or time-share contract for any domestic or overseas resort or retreat of any kind.
Securities Markets and Private Equity Financing Includes each of the following:
  • Advisor or Broker Services and Wealth or Property Management: Marketing, vending, offer, purchase, sale, transfer, exchange, issuance, or redemption of any type of SEC-nonexempt security, including any class or grade of company stock, government bond, debenture, or other, similar investment or in any special purpose vehicle (SPV), regardless of whether the customer or one or more third-party providers is performing regulated functions.
  • Exempt Securities Offerings: Marketing, offer, purchase, sale, transfer, exchange, or issuance, of any type of private or SEC-exempt security (other than a security investment in commercial real-estate development or management), including any class or grade of company stock, bond, debenture, or other, similar investment or in any special purpose vehicle (SPV), or retail securities crowdfunding.
  • Alternative Trading System Services: Operation and maintenance of an alternative trading system (ATS) to facilitate the exchange of digital or tokenized securities.
Surveillance Equipment & Other Export Controlled Sales
  • Export Controlled Goods & Services: Marketing, purchase, sale, or distribution of goods or services, domestically or abroad, that are identified on U.S. export control lists maintained under the International Traffic in Arms Regulations, 22 C.F.R. § 120 et. seq., Export Administration Regulations, 15 C.F.R., ch. VII, subch. C, and Foreign Assets Control Regulations, 15 C.F.R. pt. 500.
  • Surveillance Equipment Sales: Marketing, purchase, sale, or distribution of any kind of electronic surveillance equipment regulated under the U.S. Department of Commerce Bureau of Industry and Security’s Commerce Control List, 15 C.F.R. pt. 774.
Telecommunications or Cable Services Marketing, purchase, sale, distribution, installation, or servicing of any cable, broadband, satellite, phone, or other telecommunications services, software, or equipment of any kind.
Telemarketing Marketing, offer, sale, or solicitation of any kind of product or service primarily over the phone or via short message service (SMS) or voice messaging.
Ticketing, Reservation, or Delivery Services Marketing, purchase, sale, provision, or facilitation of any reservation, ticket, admission, or booking of any kind, or any transaction for the placement or delivery of any on-demand food, drink, or other product.
Travel Agency or Tour Operator Activities Marketing, sale, or provision of any kind of travel agency service for the arrangement of travel, tickets, reservations, or other planned activities outside the U.S.
Trust or Trust and Company Services Includes each of the following:
  • Trust and Company Services: Any transaction supporting either the provision of corporate services, including the formation or legal or financial management of any kind of business association or other entities, assets, or vehicles.
  • Trust Services: Any transaction supporting either the creation or management of any kind of trust or estate, either peer-to-peer or commercially with a trust company.
Vehicle Sales Purchase, sale, or exchange of any kind of vehicle, whole or by part, including for any car, truck, boat, yacht, all-terrain vehicle (ATV), motorcycle, moped, biped, or other motorized vehicle.
Video Rental Payment for any lease or rental of any kind of video, video game, or other media stored in a physical medium, regardless of whether distributed by a physical retail merchant, vending machine, or parcel service.

 


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Third Pillar:

Prohibited Jurisdictions

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No business or other entity is eligible to use the Services, either as a Sila customer or end user, if it is controlled by, or affiliated by common beneficial ownership with, any person or entity located in or politically or economically connected to any nation, sovereign, territory, or dependency listed below (each, a “Prohibited Jurisdiction”).

Additionally, both Sila customers and end users are strictly prohibited from using the Services to engage in or support any transaction that serves as any part of the transfer of value cross border between any U.S. state and any Prohibited Jurisdiction. Sila customers and end users also represent and warrant that they at all times comply with law and regulation with respect to sanctions, watch lists, embargoes, and export controls relevant to their business and use of the Services.

If the nature of a customer’s platform application offers the potential for any end user of the Services to engage in or give effect to any international transaction involving a Prohibited Jurisdiction, then the customer must, not only incorporate this Policy into its end user-facing terms or conditions, but, expressly prohibit transactions involving each Prohibited Jurisdiction in those terms or conditions, in writing.

Sila and its partners prohibit support for transactions and customers involved with any of these jurisdictions due either to (a) the threat of significant fraud, money laundering, or terrorist financing risks; or (b) restrictions imposed under the sanctions programs of the U.S. Treasury, Office of Foreign Assets Control (OFAC). Additionally, every customer and end user is strictly prohibited from using the Services to support any transaction involving any person or entity covered by any OFAC sanctions program.

Albania

Bailiwick of Guernsey

Bailiwick of Jersey

Belarus

Benin

Bosnia and Herzegovina

British Virgin Islands

Bulgaria

Burundi

Cayman Islands

Central African Republic

Cuba

Iran

Iraq

Isle of Man

Kosovo

Laos

Lebanon

Libya

Macedonia

Mali

Malta

Monaco

Montenegro

Mozambique

Nicaragua

Nigeria

North Korea

Pakistan

Republic of Congo

Russian Federation

Serbia

Somalia

South Sudan

Sudan and Darfur

Syria

Tanzania

Turkey

Ukraine

Venezuela

Yemen

Zimbabwe


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Fourth Pillar:

Jurisdictions Requiring Enhanced Review

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Sila customers are prohibited from using the Services or allowing end users to use the Services if controlled by (or affiliated by common beneficial ownership with) any person or entity located in (or politically or economically connected to) any nation, sovereign, territory, or dependency listed below (each, a “Restricted Jurisdiction”) except with Sila’s express prior written approval.

Additionally, Sila customers and end users are strictly prohibited from using the Services to engage in or support any transaction that serves as any part of the transfer of value cross border between any U.S. state and any Restricted Jurisdiction except with Sila’s express prior written approval.

Before granting approval to allow a customer to use the Services (either (a) as a business with any connection to or affiliation with any Restricted Jurisdiction; or (b) to support any customer or end user transactions that make up any part of the transfer of value derived from, moving through, or destined for any Restricted Jurisdiction), Sila will request, collect, and review specific documentation from the customer above and beyond what Sila and its partners require for standard customer due diligence. The customer’s supporting documentation must bolster Sila’s finding that the customer, its end users, or its platform application do not pose risks related to any Restricted Jurisdiction that would otherwise be of concern for that jurisdiction. If a customer is supporting transactions to give effect to any transfer of value involving a Restricted Jurisdiction, then the customer must demonstrate it has adequate risk-based controls necessary to ensure ongoing compliance with its independent regulatory requirements and best practices addressing risks apparent in or unique to that jurisdiction.

If the nature of a customer’s platform application offers the potential for any end user of the Services to engage in or give effect to any international transaction involving a Restricted Jurisdiction, then the customer must not only incorporate this Policy into its end user-facing terms or conditions, but expressly prohibit transactions involving each Restricted Jurisdiction in those terms or conditions, in writing.

Sila and its partners restrict support for transactions and customers involved with any of these jurisdictions due either to (a) the threat of significant fraud, money laundering, or terrorist financing risks; or (b) restrictions imposed under the sanctions programs of the U.S. Treasury, Office of Foreign Assets Control (OFAC).

Afghanistan

Algeria

Angola

Antigua and Barbuda

Argentina

Armenia

Azerbaijan

Bahamas

Bangladesh

Barbados

Belize

Bermuda

Bolivia

Botswana

Brazil

Burkina Faso

Burma (Myanmar)

Cambodia

Cameroon

China

Colombia

Croatia

Cyprus

Côte d'Ivoire

Ecuador

Gaza

Ghana

Guinea Bissau

Guyana

Haiti

Hong Kong

Iceland

Ireland

Jamaica

Jordan

Kazakhstan

Kenya

Kyrgyzstan

Liberia

Luxembourg

Macau

Mauritius

Mexico

Mongolia

Morocco

Netherlands

Panama

Paraguay

Philippines

Puerto Rico (U.S.)

Romania

Rwanda

Senegal

Sierra Leone

Singapore

Slovenia

South Africa

Switzerland

Tajikistan

Thailand

Togo

Trinidad and Tobago

Tunisia

Turkey

U.S. Virgin Islands (U.S.)

Uganda

United Arab Emirates

Uruguay

West Bank

Western Sahara



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