Acceptable Use Policy

You must use a secure encrypted connection when transmitting data to LiquidTrust, including when using APIs or integrations. You are responsible for safeguarding credentials (including API keys), maintaining appropriate access controls, and promptly notifying LiquidTrust if you discover or suspect unauthorized access to your account, your credentials, or the LiquidTrust Technology through your environment. You are responsible for maintaining appropriate backups of any content or data you provide to LiquidTrust, to the extent you maintain such records.

You agree not to, and not to allow any User or third party acting on your behalf to, take any of the following actions:

• Prohibited Content. Post, upload, publish, submit, share, distribute, or transmit any content or data that: (i) you do not have authority to provide; (ii) infringes, misappropriates, or violates a third-party's patent, copyright, trademark, trade secret, or other intellectual property rights, or rights of publicity or privacy; (iii) is fraudulent, false, misleading, deceptive, defamatory, indecent, obscene, pornographic, vulgar, or offensive; (iv) promotes discrimination, bigotry, racism, hatred, harassment, or harm against any individual or group; (v) is violent or threatening or promotes violence or actions that are threatening to any person or entity; (vi) promotes illegal or harmful activities or substances; or (vii) contains software viruses, worms, defects, Trojans, adware, spyware, malware, or other similar computer code, files, or programs designed to interrupt, destroy, or limit the functionality of any computer software or hardware device.
• Illegal Use / Rules Violations. Violate any applicable law or regulation, including AML/CTF/sanctions requirements, or the NACHA Rules or other payment network rules applicable to transactions processed through the Services.
• Unauthorized Use or Access. Use the LiquidTrust Technology or Content, or any portion thereof, (i) for any unlawful purpose, (ii) for any purpose other than bona fide business and commercial purposes, or (iii) in any manner not permitted by the Agreement.
• Other Users' Data. Collect, harvest, or store on the LiquidTrust Technology any personally identifiable information or protected health information of other users except as necessary to use the Services for legitimate transaction processing, compliance, and business recordkeeping in accordance with the Agreement and applicable law.
• Unauthorized Third-Party Processing / Payment Aggregation. Process payments on behalf of undisclosed, unauthorized, or unapproved third parties, including unauthorized payment aggregation, nested payment facilitation, or otherwise providing the Services to others as a payment service bureau, unless expressly authorized in writing by LiquidTrust.
• Fraud, Criminal Proceeds, and Evasion. Engage in any fraudulent, deceptive, or illegal practices or submit or facilitate fraudulent transactions or transactions involving proceeds of criminal activity, or attempt to disguise or misrepresent the origin, destination, purpose, or nature of transactions to evade monitoring, reporting, sanctions screening, or other legal requirements (including structuring transactions to avoid legal thresholds).
• Payment Instruction Integrity. Submit only payment instructions, beneficiary/payer/payee information, and bank or payment instrument details that you are authorized to use and that are accurate and complete; do not use stolen, unauthorized, or third-party bank account credentials; and do not submit false or misleading transaction descriptions or purpose narratives where required by law or payment network rules.
• Card Data Misuse. Store, transmit, or process payment card data in violation of PCI DSS standards or other applicable standards.
• Security and Systems Abuse. Access, tamper with, or use non-public areas of the LiquidTrust Technology or LiquidTrust's systems without authorization; probe, scan, or test the vulnerability of any LiquidTrust system or network; breach or circumvent authentication or security measures; bypass rate limits; or attempt to interfere with or disrupt the LiquidTrust Technology (including by overloading, flooding, spamming, or mail-bombing); take any action that imposes or may impose (in LiquidTrust's sole discretion) an unreasonable or disproportionately large load on the infrastructure of LiquidTrust, its Payment Processors, or Third-Party Providers; forge any TCP/IP packet header or any part of the header information in any email or newsgroup posting, or in any way use the LiquidTrust Technology or Content to send altered, deceptive, or false source-identifying information.
• Credential and API Misuse. Share credentials or API keys except with Users and authorized service providers acting on your behalf who need access to use the Services in accordance with the Agreement; or use credentials/API keys in a way that compromises security or enables unauthorized access.
• IP/Brand Misuse. Display, mirror, or frame the layout or design of the LiquidTrust Technology or any portion thereof, including LiquidTrust's name and any LiquidTrust trademark, logo, or other proprietary information, in each case, without LiquidTrust's express prior written consent; use any meta tags or other hidden text or metadata utilizing a LiquidTrust trademark, logo, URL, or product name without LiquidTrust's express written consent.
• No Unauthorized Resale / Sharing. Resell, sublicense, timeshare, or otherwise make available the LiquidTrust Technology to any third party except as expressly permitted under the Agreement or a separate written agreement with LiquidTrust (including an Integrated Partner or Customer agreement, if applicable).
• Scraping and Automated Access. Use scraping, crawling, harvesting or other unauthorized automated access methods to access or search the LiquidTrust Technology or Content or download Content from the LiquidTrust Technology, except as expressly permitted via documented APIs and in accordance with applicable rate limits and integration requirements.
• Competitive Benchmarking. Use the LiquidTrust Technology to benchmark or compare it against competing products or services for the primary purpose of competitive analysis, publication, or marketing, or to monitor availability/performance in a manner that materially degrades or disrupts the Services. This does not prohibit reasonable monitoring for your internal controls, security, and compliance purposes that does not materially impact the Services.
• Spam and Unsolicited Outreach. Send any unsolicited or unauthorized advertising, promotional materials, email, junk mail, spam, chain letters, or other form of solicitation through the LiquidTrust Technology.
• Reverse Engineering. Attempt to decipher, decompile, disassemble, reverse engineer, or otherwise attempt to derive any source code, or underlying ideas, or algorithms of any of the software used to provide the LiquidTrust Technology or Content.
• Derivative works. Modify, translate, or otherwise create derivative works of any part of the LiquidTrust Technology or Content other than your own User Content.
• Misrepresentation. Impersonate any person or entity, or misrepresent your affiliation with any person or entity.
• Encouraging Violations. Encourage, assist, allow, or enable others to do any of the foregoing.

(a) Prohibited Jurisdictions and Embargoed Regions – Tier 1 (Hard Exclusions)

You may not use the LiquidTrust Technology for any dealings, engagement, or sale of goods or services directly or indirectly with:

• Any jurisdiction subject to comprehensive sanctions or embargoes administered by the U.S. Office of Foreign Assets Control ("OFAC"), as such programs may change from time to time;
• Any embargoed region, including the Crimea region of Ukraine and the so-called Donetsk People's Republic and Luhansk People's Republic regions of Ukraine;
• Any jurisdiction identified on the Financial Action Task Force ("FATF") "High-Risk Jurisdictions Subject to a Call for Action" list ("Black-List"); or
• Any individual or entity named on any restricted person, entity, or party list of the United States, United Kingdom, European Union, Canada, Australia, Singapore, Japan, United Nations, or other jurisdictions where LiquidTrust operates.

You must not attempt to disguise or misrepresent the origin or destination of payments, goods, or services to circumvent sanctions or trade restrictions.

(b) Restricted Jurisdictions – Tier 2 (Conditional Access)

Use of the LiquidTrust Technology for dealings, engagement, or sale of goods or services - directly or indirectly - with jurisdictions identified as "high-risk" or "under increased monitoring" by FATF ("Grey-List") or on the European Union's high-risk third-country list is subject to LiquidTrust's prior written approval and enhanced due diligence ("EDD") requirements.

(c) Russia-Related Restrictions (Additional Controls)

Without limiting any other restrictions in this AUP, you may not use the LiquidTrust Technology in any manner that would cause LiquidTrust (or its financial institution partners or payment network providers) to violate applicable sanctions, export controls, or related restrictions. In particular, you may not use the LiquidTrust Technology to directly or indirectly export, re-export, sell, or supply any services that are prohibited by U.S. sanctions authorities to any person (including any individual or entity) located in the Russian Federation, including accounting services, trust and corporate formation, management consulting services, and any other categories of services covered by applicable OFAC determinations from time to time. Further, you are prohibited from using the LiquidTrust Technology in connection with any goods prohibited by law (e.g., luxury goods) from Russia.

You must not use the LiquidTrust Technology in connection with any of the following activities:

(a) Illegal products and services, including without limitation:

• Illegal drugs, substances designed to mimic illegal drugs, and equipment designed for making or using drugs
• Fake references or ID-providing services
• Telecommunications manipulation equipment including jamming devices
• Any business or organization that engages in, encourages, promotes or celebrates (i) unlawful violence or physical harm to persons or property, or (ii) unlawful violence toward any group based on race, religion, disability, gender, sexual orientation, national origin, or any other immutable characteristic
• Any other products or services that are in violation of law in the jurisdictions where your business is located or targeted to
• Products and services that infringe intellectual property rights

(b) Sales or distribution of music, movies, software, or any other licensed materials without appropriate authorization, including without limitation:

• Counterfeit goods and illegally imported or exported products
• Unauthorized sale of brand name or designer products or services
• Any other products or services that indirectly or directly infringe or facilitate infringement of the intellectual property, proprietary or privacy rights of any third party

(c) Products and services that are unfair, predatory, or deceptive, including without limitation:

• Pyramid schemes
• '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 up front work, and sites that promise fast and easy money
• Sales of online traffic or engagement
• Negative response marketing and telemarketing
• Predatory mortgage consulting, lending, credit repair and counseling services
• Predatory investment opportunities with no or low money down
• Remote technical support, mugshot publication or pay-to-remove sites, chain letters, door-to-door sales
• Any other activities that are unfair, deceptive, or predatory, in LiquidTrust's sole discretion

(d) Adult content and services

• Pornography and other mature audience content (including literature, imagery and other media) depicting nudity or explicit sexual acts
• Adult services including prostitution, escorts, pay-per view, sexual massages, and adult live chat features
• Adult video stores
• Gentleman's clubs, topless bars, and strip clubs

(e) Certain legal services

• Law firms collecting funds for purposes other than legal service fee payment
• Bankruptcy attorneys
• Bail bonds

(f) Firearms, explosives, and hazardous materials

• Guns, gunpowder, ammunitions, weapons, fireworks and other explosives
• Peptides, research chemicals, and other toxic, flammable and radioactive materials

(g) Gambling with monetary or material prizes

• Games of chance including gambling, internet gambling, sweepstakes and contests, fantasy sports leagues
• Games of skill including video game and mobile game tournaments/competitions, card games, board games
• To process payments for an entry/player fee that promises the entrant/player to win a prize in money or money's worth, or to payout winnings of such games
• Sports forecasting or odds making with a monetary or material prize
• Lotteries
• Bidding fee auctions

(h) Marijuana or cannabis-related products

(i) Misuse of the LiquidTrust Technology

• Use of the LiquidTrust Technology with false, manipulated, inaccurate, or misleading information regarding your identity, business entity, the nature of business, and any other information requested by LiquidTrust
• Fraudulent transactions or transactions involving the proceeds of criminal activity
• Processing where there is no bona fide good or service sold
• Use of LiquidTrust intellectual property without prior written consent from LiquidTrust; use of the LiquidTrust name or logo in a manner that otherwise harms LiquidTrust or the LiquidTrust brand; any action that implies an untrue endorsement by or affiliation with LiquidTrust
• Trade-based money laundering risks, including transactions involving shell companies, anonymous ownership structures, or unverified counterparties
• High-risk payment channels, including unlicensed money services businesses, hawala-type arrangements, or unregistered remittance operators

The types of activities listed above are representative but not exhaustive.

You must not use the LiquidTrust Technology for the following restricted activities without prior written approval. If your business falls into one of the restricted categories, please contact us at support@liquidtrust.io:

(a) Financial products/services

• Investment and brokerage services
• Lending services
• Buy Now Pay Later and similar services
• Lending, crowdfunding, debt collection
• Insurance services including medical benefit packages
• Money transmitters, currency exchange services and other money services businesses
• Neobanks / challenger banks
• Other financial institutions

(b) Government services

• Government grants
• Embassy, foreign consulate, or other foreign governments

(c) Cannabidiol (CBD) products containing negligible amounts of THC

(d) Pharmaceuticals, medical devices, and telemedicine

• Online pharmacies
• Prescription-only products including card-not-present pharmaceuticals
• Prescription-only and regulated medical devices
• Telemedicine and telehealth services

(e) Tobacco products including e-cigarettes and e-liquid

(f) Non-fiat currency and stored value

• Virtual and cryptocurrencies, non-fungible tokens (NFTs), and mining services
• Prepaid phone cards, sim cards, and phone services
• Sale of stored value or credits maintained, accepted and issued by anyone other than the seller
• Sale of in-game currency or game items, unless the merchant is the operator of the virtual world

(g) Multi-level marketing

• Businesses where sellers get their revenue both from selling items and from signing up new sellers
• Network marketing and referral marketing programs

(h) Others

• Charity sweepstakes and raffles
• Credit card and identity theft protection services
• Other age restricted goods or services

The types of businesses listed above are representative but not exhaustive.

You may not use or facilitate the use of the LiquidTrust Technology to violate the security or integrity of any network, computer or communications system, software application, or other network-attached device. You may not:

• Access or attempt to access any system without authorization.
• Conduct unauthorized port scanning or vulnerability testing. You may not make or attempt to make network connections to any systems, networks, or network devices for which you don't have authorization.
• Jeopardize the security of the LiquidTrust Technology or other customers.

You are responsible for any security incidents or data breaches arising from your systems or from third parties you authorize to access the LiquidTrust Technology.

LiquidTrust may monitor and review activity and may delay, block, or refuse transactions to comply with laws or if suspicious activity is detected.

We reserve the right to investigate any suspected violation of this AUP or misuse of the LiquidTrust Technology. Upon reasonable notice, LiquidTrust may request information and documentation reasonably necessary to support compliance, risk management, transaction monitoring, sanctions screening, and investigations, subject to confidentiality and security requirements and to the extent such information is within your possession or control. LiquidTrust will not require you to disclose security-sensitive information or information prohibited from disclosure by law. We may report any actual or suspected violations to law enforcement, regulators, or other appropriate third parties.

8.1 LiquidTrust may suspend or terminate your access to the LiquidTrust Technology for AUP violations with or without notice as permitted under the Agreement and applicable law.

8.2 Any suspension or termination of access to the LiquidTrust Technology due to a violation of this AUP shall not entitle you to any refund of any fees paid to us prior to suspension or termination. We are not liable for damages of any nature resulting in whole or in part from the exercise of our rights under this AUP, including any damages arising from suspension or termination.

A.1 OFAC Comprehensive Sanctions List

For purposes of Tier 1, "jurisdictions subject to comprehensive sanctions or embargoes" means any country or region listed under OFAC's country/program sanctions that imposes a full trade embargo.

Current list: OFAC Sanctions Programs and Country Information

A.2 FATF "Call for Action" List (Black-List)

For purposes of Tier 1, this is the FATF list of jurisdictions subject to countermeasures due to serious deficiencies in anti-money laundering ("AML") and counter-terrorist financing ("CTF") measures.

Current list: FATF High-Risk Jurisdictions Subject to a Call for Action

A.3 FATF "Increased Monitoring" List (Grey-List)

For purposes of Tier 2, this is the FATF list of jurisdictions actively working with FATF to address strategic deficiencies in their AML/CTF regimes.

Current list: FATF Jurisdictions Under Increased Monitoring

A.4 EU High-Risk Third-Country List

For purposes of Tier 2, this is the European Union list of third countries with strategic deficiencies in their AML/CTF regimes that pose significant threats to the financial system.

Current list: EU High-Risk Third Countries

A.5 Catch-All Provision

If a jurisdiction or entity becomes sanctioned, embargoed, or otherwise restricted by any of the above bodies after the effective date of this AUP, it will be considered part of the relevant Tier immediately upon listing, regardless of whether it is explicitly named in this document.

Contact: For questions regarding this AUP, contact support@liquidtrust.io.