Политика приостановки действия учетной записи

Последнее обновление: Июнь 24, 2026

Last Updated: 15 June 2026

This Account Suspension, Restriction, Freeze, Reserve and Termination Policy (“Policy”) forms an integral part of the Terms and Conditions and applies to all Clients, Users, Accounts, Cards, transactions, balances, payment credentials, services, and activities conducted through the Platform.

By using the Services, the Client expressly acknowledges, understands, and accepts this Policy in its entirety.

The Company reserves the unrestricted right to apply any restriction, limitation, suspension, reserve, hold, freeze, investigation, review, or termination measure described herein whenever deemed necessary by the Company, its Issuers, banking partners, processors, compliance providers, regulators, payment schemes, or infrastructure providers.

1. PURPOSE OF THIS POLICY

The purpose of this Policy is to:

(a) protect the integrity of the Services;

(b) protect Issuers and banking partners;

(d) prevent fraud and abuse;

(e) ensure compliance with Applicable Law;

(f) ensure compliance with AML and CTF obligations;

(g) reduce financial, regulatory, operational, reputational, legal, and counterparty risks;

(h) protect the Company and its partners from losses.

The Company may apply measures under this Policy regardless of whether any actual violation has occurred.

Reasonable suspicion alone may be sufficient.

2. TYPES OF RESTRICTIONS

The Company may impose one or more of the following measures:

(a) account review;

(b) account limitation;

(d) spending limitation;

(e) withdrawal limitation;

(f) funding limitation;

(g) card limitation;

(h) merchant restriction;

(i) MCC restriction;

(j) geographic restriction;

(k) reserve placement;

(l) rolling reserve;

(m) fixed reserve;

(n) temporary hold;

(o) balance freeze;

(p) transaction reversal;

(q) card suspension;

(r) card cancellation;

(s) account suspension;

(t) account termination;

(u) permanent ban;

(v) future onboarding prohibition;

(w) enhanced compliance review;

(x) enhanced monitoring.

The Company may combine multiple restrictions simultaneously.

3. EVENTS THAT MAY TRIGGER A REVIEW

A review may be initiated at any time including, without limitation, where:

(a) unusual transaction activity is detected;

(b) spending patterns materially change;

(d) transaction amounts increase unexpectedly;

(e) transaction behavior differs from historical behavior;

(f) chargebacks increase;

(g) decline ratios increase;

(h) fraud indicators appear;

(i) compliance alerts are generated;

(j) sanctions screening alerts are generated;

(k) adverse media reports are identified;

(l) law enforcement inquiries are received;

(m) regulatory requests are received;

(n) issuer requests are received;

(o) processor requests are received;

(p) merchant complaints are received;

(q) third party complaints are received;

(r) suspicious login activity occurs;

(s) account takeover indicators are detected;

(t) unauthorized access is suspected;

(u) payment network monitoring flags activity;

(v) internal risk models detect elevated risk.

No minimum threshold is required.

4. IMMEDIATE ACCOUNT SUSPENSION EVENTS

The Company may immediately suspend an Account without notice where any of the following occur:

(a) suspected fraud;

(b) suspected money laundering;

(d) sanctions exposure;

(e) suspicious source of funds;

(f) suspicious source of wealth;

(g) forged documentation;

(h) false information provided during onboarding;

(i) identity discrepancies;

(j) account sharing;

(k) unauthorized access;

(l) card testing activity;

(m) excessive declines;

(n) phishing activity;

(o) malware activity;

(p) deceptive advertising activity;

(q) prohibited business activity;

(r) unauthorized third party usage;

(s) repeated compliance failures;

(t) attempts to circumvent restrictions;

(u) direct contact with Issuers or banking partners.

Suspension may remain in place indefinitely.

5. BALANCE FREEZES

The Company may freeze all or part of any balance where:

(a) an investigation is ongoing;

(b) compliance review is pending;

(d) fraud exposure exists;

(e) suspicious activity exists;

(f) reserve requirements apply;

(g) regulatory obligations require retention of funds;

(h) issuer instructions are received;

(i) processor instructions are received;

(j) court orders are received;

(k) law enforcement requests are received.

Frozen balances may not be accessible during review.

No interest shall accrue on frozen funds.

6. RESERVES

The Company may establish reserves at any time.

Reserves may include:

(a) rolling reserves;

(b) fixed reserves;

(d) transaction-specific reserves;

(e) account-wide reserves;

(f) merchant-specific reserves.

Reserve percentages may range from 1% to 100%.

Reserve periods may range from one day to an indefinite period.

The Company is under no obligation to disclose reserve methodologies.

7. ENHANCED DUE DILIGENCE REVIEWS

The Company may require additional documentation including:

(a) source of funds evidence;

(b) source of wealth evidence;

(d) accounting records;

(e) invoices;

(f) contracts;

(g) customer records;

(h) advertising records;

(i) supplier records;

(j) beneficial ownership documentation;

(k) corporate records;

(l) bank statements;

(m) wallet ownership verification;

(n) video verification;

(o) live interviews;

(p) notarized documents;

(q) apostilled documents.

The Company may repeat requests at any time.

Previously approved documentation may be requested again.

8. CLIENT COOPERATION REQUIREMENTS

The Client shall fully cooperate with all investigations.

The Client shall provide requested information within the timeframe specified by Support.

Failure to cooperate may result in:

(a) suspension;

(b) reserve placement;

(d) termination;

(e) refusal of withdrawals;

(f) permanent restrictions.

The Company shall determine sufficiency of cooperation in its sole discretion.

9. HIGH-RISK ACTIVITIES

The following activities are considered inherently high risk:

(a) cryptocurrency services;

(b) digital asset trading;

(d) media buying;

(e) lead generation;

(f) subscription services;

(g) software licensing;

(h) digital goods;

(i) online education;

(j) consulting services;

(k) high-volume advertising activity;

(l) cross-border payments;

(m) marketplace activity;

(n) reseller operations.

Participation in high-risk activities may result in increased monitoring, reserves, and restrictions.

10. DIRECT CONTACT VIOLATIONS

Any attempt by a Client to contact:

(a) an Issuer;

(b) sponsoring bank;

(d) processor;

(e) acquiring institution;

(f) payment scheme;

(g) compliance provider;

(h) infrastructure provider;

(i) banking partner;

(j) employee of such entities

without prior written authorization from the Company shall constitute a material breach.

Such breach may result in:

(a) immediate account termination;

(b) permanent freeze of services;

(d) internal blacklist placement;

(e) reporting to counterparties.

11. TERMINATION OF ACCOUNT

The Company may terminate any Account at any time with or without notice.

Termination may occur where:

(a) risk becomes unacceptable;

(b) compliance concerns arise;

(d) reputational concerns arise;

(e) business strategy changes;

(f) issuer requirements change;

(g) processor requirements change;

(h) regulatory requirements change;

(i) infrastructure changes occur;

(j) any reason deemed appropriate by the Company.

The Company shall not be obligated to provide an explanation.

12. POST-TERMINATION HOLDS

Following termination, funds may remain subject to:

(a) reserves;

(b) compliance reviews;

(d) fraud investigations;

(e) legal obligations;

(f) regulatory requirements.

Such holds may continue for up to 365 days or longer where required by Applicable Law, counterparties, regulators, payment networks, Issuers, or ongoing investigations.

13. NO RIGHT TO APPEAL

The Client acknowledges and agrees that:

(a) restrictions may be imposed without prior notice;

(b) restrictions may be imposed without explanation;

(d) internal risk methodologies are proprietary;

(e) compliance determinations are confidential;

(f) fraud determinations are confidential;

(g) suspension decisions are final;

(h) termination decisions are final.

The Company is not obligated to disclose evidence, internal assessments, risk scores, screening results, monitoring methodologies, or investigative findings.

14. RELEASE OF FUNDS

Release of funds following a suspension, reserve, hold, or termination shall occur solely at the discretion of the Company and subject to:

(a) completion of all compliance reviews;

(b) completion of all fraud reviews;

(d) satisfaction of all liabilities;

(e) receipt of all requested documentation;

(f) approval from applicable counterparties where required.

The Company makes no guarantee regarding release timelines.

15. FINAL ACKNOWLEDGEMENT

By using the Services, the Client expressly acknowledges and agrees that:

(a) access to the Services is a revocable privilege and not a right;

(b) the Company may suspend, restrict, freeze, reserve, investigate, or terminate access at any time;

(d) compliance reviews may occur repeatedly;

(e) risk assessments are determined solely by the Company;

(f) all decisions under this Policy are final, binding, and non-appealable;

(g) the Client assumes all risks associated with the Services.