Restricted & Prohibited Business Areas
Triple-A is dedicated to promoting a safe and responsible financial ecosystem and is committed to upholding the highest standards of ethical conduct and complying with all applicable laws and regulations. To that end, this policy has been established to guide Triple-A’s partners and merchants in understanding the types of activities and products that are explicitly prohibited or subject to significant restrictions within our platform.
As such, any activity that engages in or facilitates activities that are deemed illegal or unlawful in any applicable jurisdiction is strictly prohibited. This policy is not exhaustive. We reserve the right to prohibit any activity or product that we deem damaging to our reputation, even if it does not fall into the below categories. We undertake to comply with all applicable laws and regulations in the jurisdictions in which we operate. This means that we may have to prohibit certain activities or products based on local regulations, even if they are not explicitly listed in this policy. For example, in general, “Commerce of tobacco products, including cigarettes, e-cigarettes and e-liquids” is deemed as restricted by Triple-A in most of the cases. However, commerce of vaping products, including e-cigarettes and other electronic nicotine delivery systems (ENDS) is specifically prohibited in Singapore.
At Triple-A, we welcome all legitimate businesses. However, some sectors require additional scrutiny due to their inherent risk profile. These sectors, defined as restricted, may be more susceptible to financial crime. To ensure financial integrity and comply with international regulations, we will implement enhanced due diligence procedures for businesses in these sectors. This may include requesting additional documentation, verifying licensing/registration status, conducting in-depth reviews, and implementing stricter monitoring practices according to our policies and procedures.
Differentiated Restrictions and Prohibitions by Business Relationship
The specific restrictions and prohibitions outlined in this policy vary depending on a partner's business model. We categorise our partners into two main groups:
1. Direct Merchant:
- A direct merchant is an entity onboarded directly to Triple-A and sells products/services in its own name and bears full responsibility for its operations.
- The restricted and prohibited industries for the direct merchants are outlined in the below table, under column “Direct Merchant”.
2. PSP/Marketplace:
- A PSP/Marketplace is an entity onboarded to Triple-A and onboards/facilitates other sub-merchants that sell products/services.
- The restricted and prohibited industries for PSP/Marketplace are outlined in the table below, under “PSP/Marketplace”. The restrictions and prohibitions applicable to PSP/Marketplace are more stringent than those for direct merchants, and are subject to more direct oversight by Triple-A.
- PSP is not allowed to onboard other nested PSPs or route the volume to Triple-A.
- In this policy, PSP includes MSB, MVTS, VASP and EMI, etc.
Adult Content & Services
Direct | PSP or | |
Services of a sexual nature on-site | Prohibited | Prohibited |
Adult content and services off-site | Restricted | Prohibited |
REGULATED SUBSTANCES OR OTHER PRODUCTS AND SERVICES PRESENTING A RISK TO CONSUMER SAFETY
Direct | PSP or | |
CBD products | Restricted | Prohibited |
Marijuana Products | Restricted | Prohibited |
Pharmaceutical products and services | Restricted | Restricted |
Hazardous materials e.g. peptides, research chemicals, bacteria cultures | Prohibited | Prohibited |
Commerce of alcohol | Restricted | Restricted |
Commerce of tobacco products, including cigarettes, e-cigarettes and e-liquids | Restricted | Restricted |
SPECIFIC LEGAL ENTITIES, BODIES AND STRUCTURES PRESENTING AN INCREASED RISK OF BRIBERY, CORRUPTION AND ML/TF
Direct | PSP or | |
Shell banks | Prohibited | Prohibited |
Shell companies | Prohibited | Prohibited |
Bearer shares entities, nominee/trust structures and other similar structures designed to conceal the identity of the beneficial owner(s) | Prohibited | Prohibited |
Charities, social service organisations and other non-profit or political organisations | Restricted | Restricted |
Embassy, consulates and other governmental institutions or services | Restricted | Prohibited |
OTHER DESIGNATED NON-FINANCIAL BUSINESSES AND PROFESSIONS
Direct | PSP or | |
Art and antiques dealer | Restricted | Restricted |
Precious metals and stones dealer | Restricted | Restricted |
Used car and other first-hand vehicle dealer | Restricted | Restricted |
Other high-value goods dealer | Restricted | Restricted |
Gambling products and services | Restricted | Restricted |
Real estate services | Restricted | Restricted |
Lawyers, notaries, accountants, auditors, tax advisors and other independent legal professionals | Restricted | Restricted |
Trusts and Corporate Service Providers | Restricted | Restricted |
FINANCIAL ACTIVITIES
Direct | PSP or | |
Financial products and services including but not limited to, consumer finance, banking, insurance, payments, remittance, securities and trading | Restricted | Prohibited |
Unlicensed/unregulated PSPs | Prohibited | Prohibited |
Crowdfunding / Crowdlending | Restricted | Prohibited |
Bidding fee auctions/penny auctions | Prohibited | Prohibited |
Sale and marketing of Binary Options | Prohibited | Prohibited |
Provider or seller of prepaid access/stored value | Restricted | Prohibited |
Independent or unlicensed financial advisors | Prohibited | Prohibited |
OTHER RESTRICTED AND PROHIBITED ACTIVITIES
Direct | PSP or | |
Trade of weapons, ammunitions, military arms, explosive devices and firearm parts, other explosives and dangerous materials | Prohibited | Prohibited |
Live-streaming Services with in-app currency/donations functionality | Restricted | Restricted |
Unfair, predatory or deceptive products and services, including, but not limited to, multi-level marketing, pyramid schemes, unreasonably high reward schemes, referral marketing, etc. | Prohibited | Prohibited |
Trade in restricted and/or endangered animal species and derived products | Prohibited | Prohibited |
Human body parts or bodily fluids | Prohibited | Prohibited |
Extraction of Natural resources / energy industry such as oil, natural gas, nuclear, minerals | Prohibited | Prohibited |