Customer Acceptance guidelines

The purpose of this document is to provide guidance concerning the topic of Client Acceptance:

1. Which Business Types Clarity Global would not accept.
2. Which business types can Clarity Global accept, and whether we classify these as High, Medium, or Low Risk.
3. Jurisdictions non - acceptable
4. Jurisdictions - acceptable



When determining which industries to accept for onboarding, Clarity Global uses various factors, in particular:

1. What are the Global regulations of the industry?
2. Which level of Risk does the industry represent?
3. Is working with this industry within the Company’s Risk appetite?
4. Is working with this industry within the Company’s Partners’ Risk appetite?
5. In which country is the client located or incorporated?
6. In which countries do the company officials reside?

First
Prohibited Businesses
Restricted Businesses
Not Acceptable Countries
Restricted Countries

The purpose of this document is to provide guidance concerning the topic of Client Acceptance:

1. Which Business Types Clarity Global would not accept.
2. Which business types can Clarity Global accept, and whether we classify these as High, Medium, or Low Risk.
3. Jurisdictions non - acceptable
4. Jurisdictions - acceptable



When determining which industries to accept for onboarding, Clarity Global uses various factors, in particular:

1. What are the Global regulations of the industry?
2. Which level of Risk does the industry represent?
3. Is working with this industry within the Company’s Risk appetite?
4. Is working with this industry within the Company’s Partners’ Risk appetite?
5. In which country is the client located or incorporated?
6. In which countries do the company officials reside?

This section provides industries which Clarity Global would not accept for onboarding according to its Risk appetite, Regulation restrictions or other reasons.

The list is not exhaustive - Clarity Global may amend the list according to changed Risk Appetite, updates in regulatory framework or other reasons.

Clarity Global would not accept any business conducting illegal activities, even if it is not in the list below.

№
Definition
1
Adult entertainment, website or contents such as:
• Adult escorts, prostitution services and massage parlours
• Child pornography
• Bestiality
• Forced Sex/ Rape
• Violence/ Humiliation
• Male or female sexual enhancement supplements or products
• Video texting or paid subscriptions to live-streaming where it involves adult erotic content or conversations
• Gentleman’s clubs, strip clubs and topless bars
2
Counterfeit items
3
Credit repair services
4
Drugs or drug proprietors selling illegal substances
5
Drug paraphernalia that involves equipment designed for making or using drugs
6
Marijuana, CBD/THC related products and businesses
7
Human remains and body parts
8
Human trafficking
9
Child exploitation
10
Wildlife trade
11
Products and services facilitating animal cruelty
12
Mail-order brides services
13
Poisonous and hazardous materials
14
Products/services promoting abuse, hatred, racism, religious persecution, terrorism, violence or contain offensive content
15
Pyramid or ponzi schemes
16
Sanction list inclusions (global)
17
Shell banks and companies
18
Signal jammers/blockers that interferes with cellular/communication devices
19
Products and services that infringe intellectual property rights
20
Mining and extraction of minerals, precious metals and stones
21
Surrogacy services
22
Tattoo parlors
23
Trade of weapons, ammunitions, military armaments, explosive devices and firearm parts
24
Corporates with bearer share
25
Timeshare services
26
Pawn shops
27
Non-governmental organizations
28
Generation, distribution and transmission of nuclear power, processing of nuclear fuel
29
Get rich quick schemes including investment opportunities or other services that promise high rewards to mislead consumers; schemes that claim to offer high rewards for very little effort or upfront work; sites that promise fast and easy money. Remote computer assistance
30
Manufacture of explosives
31
Manufacture of mortars
32
Manufacture of weapons and ammunition
33
Manufacture of military fighting vehicles
34
Illegal business on any type
35
Business where Director and/ or UBO and or/ Shareholder and/ or Senior management representative are subject to sanctions
36
Business where Director and/ or UBO and or/ Shareholder and/ or Senior management representative is a Politically exposed person (PEP)

Clarity Global will apply Enhanced Due Diligence to clients operating in the following businesses:

№
Definition
1
Growing of spices, aromatic, drug and pharmaceutical crops
2
Manufacture of fertilizers and nitrogen compounds
3
Manufacture of pesticides and other agrochemical products
4
Manufacture of other chemical products n.e.c.
5
Manufacture of basic pharmaceutical products
6
Manufacture of pharmaceutical preparations
7
Striking of coins
8
Manufacture of jewellery and related articles
9
Sale of used cars and light motor vehicles
10
Sale of other motor vehicles
11
Sale, maintenance and repair of motorcycles and related parts and accessories
12
Agents involved in the sale of fuels, ores, metals and industrial chemicals
13
Wholesale of pharmaceutical goods
14
Wholesale of watches and jewellery
15
Wholesale of chemical products
16
Retail sale of watches and jewellery in specialised stores
17
Retail sale in commercial art galleries
18
Retail sale of antiques including antique books in stores
19
Banks
20
Building societies
21
Activities of agricultural holding companies
22
Activities of production holding companies
23
Activities of construction holding companies
24
Activities of distribution holding companies
25
Activities of financial services holding companies
26
Activities of other holding companies n.e.c.
27
Activities of investment trusts
28
Activities of unit trusts
29
Activities of venture and development capital companies
30
Activities of open-ended investment companies
31
Activities of property unit trusts
32
Activities of real estate investment trusts
33
Financial leasing
34
Credit granting by non-deposit taking finance houses and other specialist consumer credit grantors
35
Activities of mortgage finance companies
36
Other credit granting n.e.c.
37
Security dealing on own account
38
Factoring
39
Financial intermediation not elsewhere classified
40
Life insurance
41
Non-life insurance
42
Life reinsurance
43
Non-life reinsurance
44
Pension funding
45
Administration of financial markets
46
Security and commodity contracts dealing activities
47
Activities auxiliary to financial intermediation n.e.c.
48
Risk and damage evaluation
49
Activities of insurance agents and brokers
50
Other activities auxiliary to insurance and pension funding
51
Fund management activities
52
Financial management
53
Gambling and betting activities
54
Activities of religious organisations
55
Activities of political organisations
56
Repair of watches, clocks and jewellery
57
Online pharmaceuticals stores

Types of businesses, which have not been mentioned in sections 1 and 2 above, are generally acceptable by Clarity Global.

Clarity Global does not establish business relations with Companies incorporated and/or located or individuals residing in the following countries:

Clarity Global regularly updates the above list based on the latest United Nations Security Council Sanctions (as published at https://www.un.org/securitycouncil/content/un-sc-consolidated-list) and the latest guidelines of the FATF (published at http://www.fatfgafi.org/countries/).

Clarity Global will apply an Enhanced Due Diligence to clients incorporated, located or having business relations with the following countries:

The list is not exhaustive - Clarity Global may amend the list according to changed Risk Appetite, updates in regulatory framework or other reasons

Prohibited Businesses

This section provides industries which Clarity Global would not accept for onboarding according to its Risk appetite, Regulation restrictions or other reasons.

The list is not exhaustive - Clarity Global may amend the list according to changed Risk Appetite, updates in regulatory framework or other reasons.

Clarity Global would not accept any business conducting illegal activities, even if it is not in the list below.

№
Definition
1
Adult entertainment, website or contents such as:
• Adult escorts, prostitution services and massage parlours
• Child pornography
• Bestiality
• Forced Sex/ Rape
• Violence/ Humiliation
• Male or female sexual enhancement supplements or products
• Video texting or paid subscriptions to live-streaming where it involves adult erotic content or conversations
• Gentleman’s clubs, strip clubs and topless bars
2
Counterfeit items
3
Credit repair services
4
Drugs or drug proprietors selling illegal substances
5
Drug paraphernalia that involves equipment designed for making or using drugs
6
Marijuana, CBD/THC related products and businesses
7
Human remains and body parts
8
Human trafficking
9
Child exploitation
10
Wildlife trade
11
Products and services facilitating animal cruelty
12
Mail-order brides services
13
Poisonous and hazardous materials
14
Products/services promoting abuse, hatred, racism, religious persecution, terrorism, violence or contain offensive content
15
Pyramid or ponzi schemes
16
Sanction list inclusions (global)
17
Shell banks and companies
18
Signal jammers/blockers that interferes with cellular/communication devices
19
Products and services that infringe intellectual property rights
20
Mining and extraction of minerals, precious metals and stones
21
Surrogacy services
22
Tattoo parlors
23
Trade of weapons, ammunitions, military armaments, explosive devices and firearm parts
24
Corporates with bearer share
25
Timeshare services
26
Pawn shops
27
Non-governmental organizations
28
Generation, distribution and transmission of nuclear power, processing of nuclear fuel
29
Get rich quick schemes including investment opportunities or other services that promise high rewards to mislead consumers; schemes that claim to offer high rewards for very little effort or upfront work; sites that promise fast and easy money. Remote computer assistance
30
Manufacture of explosives
31
Manufacture of mortars
32
Manufacture of weapons and ammunition
33
Manufacture of military fighting vehicles
34
Illegal business on any type
35
Business where Director and/ or UBO and or/ Shareholder and/ or Senior management representative are subject to sanctions
36
Business where Director and/ or UBO and or/ Shareholder and/ or Senior management representative is a Politically exposed person (PEP)
Restricted Businesses

Clarity Global will apply Enhanced Due Diligence to clients operating in the following businesses:

№
Definition
1
Growing of spices, aromatic, drug and pharmaceutical crops
2
Manufacture of fertilizers and nitrogen compounds
3
Manufacture of pesticides and other agrochemical products
4
Manufacture of other chemical products n.e.c.
5
Manufacture of basic pharmaceutical products
6
Manufacture of pharmaceutical preparations
7
Striking of coins
8
Manufacture of jewellery and related articles
9
Sale of used cars and light motor vehicles
10
Sale of other motor vehicles
11
Sale, maintenance and repair of motorcycles and related parts and accessories
12
Agents involved in the sale of fuels, ores, metals and industrial chemicals
13
Wholesale of pharmaceutical goods
14
Wholesale of watches and jewellery
15
Wholesale of chemical products
16
Retail sale of watches and jewellery in specialised stores
17
Retail sale in commercial art galleries
18
Retail sale of antiques including antique books in stores
19
Banks
20
Building societies
21
Activities of agricultural holding companies
22
Activities of production holding companies
23
Activities of construction holding companies
24
Activities of distribution holding companies
25
Activities of financial services holding companies
26
Activities of other holding companies n.e.c.
27
Activities of investment trusts
28
Activities of unit trusts
29
Activities of venture and development capital companies
30
Activities of open-ended investment companies
31
Activities of property unit trusts
32
Activities of real estate investment trusts
33
Financial leasing
34
Credit granting by non-deposit taking finance houses and other specialist consumer credit grantors
35
Activities of mortgage finance companies
36
Other credit granting n.e.c.
37
Security dealing on own account
38
Factoring
39
Financial intermediation not elsewhere classified
40
Life insurance
41
Non-life insurance
42
Life reinsurance
43
Non-life reinsurance
44
Pension funding
45
Administration of financial markets
46
Security and commodity contracts dealing activities
47
Activities auxiliary to financial intermediation n.e.c.
48
Risk and damage evaluation
49
Activities of insurance agents and brokers
50
Other activities auxiliary to insurance and pension funding
51
Fund management activities
52
Financial management
53
Gambling and betting activities
54
Activities of religious organisations
55
Activities of political organisations
56
Repair of watches, clocks and jewellery
57
Online pharmaceuticals stores
Not Acceptable Countries

Clarity Global will apply an Enhanced Due Diligence to clients incorporated, located or having business relations with the following countries:

Clarity Global regularly updates the above list based on the latest United Nations Security Council Sanctions (as published at https://www.un.org/securitycouncil/content/un-sc-consolidated-list) and the latest guidelines of the FATF (published at http://www.fatfgafi.org/countries/).

Restricted Countries

Clarity Global will apply an Enhanced Due Diligence to clients incorporated, located or having business relations with the following countries:

The list is not exhaustive - Clarity Global may amend the list according to changed Risk Appetite, updates in regulatory framework or other reasons