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
Merchant

PSP or
Marketplace

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
Merchant

PSP or
Marketplace

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
Merchant

PSP or
Marketplace

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
Merchant

PSP or
Marketplace

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
Merchant

PSP or
Marketplace

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
Merchant

PSP or
Marketplace

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

Payments for a Digital World.

Licensed as a Major Payment Institution (MPI) by MAS, the Monetary Authority of Singapore.

License number: PS20200525

Licensed as a Payment Institution by the ACPR and registered as a Digital Asset Service Provider by the AMF under the aegis of Banque de France.

LEI: 969500VA4A8CRCS2N988

DASP LEI: E2023-079

Registered with the U.S. as Triple A Technologies Inc. (NMLS ID: 2514255) and through FinCEN as Money Service Business (31000261257720). Licensed as a money transmitter in various U.S. States.

NMLS ID: 2514255

MSB: 31000261257720

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