All users must comply with this Acceptable Use Policy (“AUP”) in connection with access or use of the Platform, Site, or Services (individually and collectively, the “LiquidTrust Technology”) provided by Liquid Global, Inc., its subsidiaries, and affiliates (collectively, “LiquidTrust”). Your use of the LiquidTrust Technology constitutes your acceptance of the most current version of this AUP. It is your responsibility to ensure that you and all of your Users comply with this AUP at all times. LiquidTrust reserves the right to make changes to this AUP at any time, and without notice.

Capitalized terms used herein and not otherwise defined shall have the meaning ascribed to them in the LiquidTrust Terms of Service (the “Agreement”).

In addition to the requirements set out below, you must comply at all times with all applicable anti-money laundering (“AML”), counter-terrorism financing (“CTF”), and sanctions laws and regulations in all jurisdictions where you operate or where payments are sent or received.

You agree to promptly provide any information or documentation requested by LiquidTrust for purposes of regulatory compliance, transaction monitoring, sanctions screening, or investigation of potential AUP violations.

1. User Content

You must use a secure encrypted connection when transmitting User Content. You are responsible for making backups, safeguarding passwords, and limiting access to your accounts, computers, and devices.

2. Unacceptable Use

You agree not to take any of the following actions: 

• Post, upload, publish, submit, share, distribute, or transmit any User Content: (i) for which you lack the authority to do so; (ii) that 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) that is fraudulent, false, misleading, deceptive, defamatory, indecent, obscene, pornographic, vulgar, or offensive; (iv) that promotes discrimination, bigotry, racism, hatred, harassment, or harm against any individual or group; (v) that is violent or threatening or promotes violence or actions that are threatening to any person or entity; (vi) that promotes illegal or harmful activities or substances; or (vii) that 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.

• Violate any applicable law, regulation or NACHA Rules.

• Use the LiquidTrust Technology or Content, or any portion thereof, (i) for any unlawful purpose, (ii) for any purpose other than your business purposes, or (iii) for the benefit of any third party or in any manner not permitted by the Agreement or this AUP.

• Engage in any fraudulent, deceptive, or illegal practices or activities, or use the LiquidTrust Technology to directly or indirectly support any such practices or activities.

• Submit or facilitate fraudulent transactions or transactions involving the proceeds of criminal activity.

• Circumvent transaction monitoring or reporting thresholds, including structuring transactions to avoid laws.

• Process payments on behalf of undisclosed or unauthorized third parties, including unauthorized payment aggregation.

• Store, transmit, or process payment card data in violation of PCI DSS standards.

• Access, tamper with, or use non-public areas of the LiquidTrust Technology or LiquidTrust’s systems without authorization.

• 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.

• Resell, sublicense, timeshare, or otherwise share the LiquidTrust Technology with any third party.

• Interfere with, attempt to interfere with, or disrupt the LiquidTrust Technology.

• 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.

• Use scraping, crawling, or other unauthorized automated access methods to access or search the LiquidTrust Technology or Content or download Content from the LiquidTrust Technology.

• Harvest or scrape any Content from the LiquidTrust Technology.

• Probe, scan, or test the vulnerability of any LiquidTrust system or network or breach any security or authentication measures

• Avoid, bypass, remove, deactivate, impair, descramble, or otherwise circumvent any technological measure implemented by LiquidTrust or any of LiquidTrust’s providers or any other party (including another user) to protect the LiquidTrust Technology or Content.

• Access or use the LiquidTrust Technology for the purposes of monitoring its availability, performance, or functionality, or for any other benchmarking or competitive purposes.

• Send any unsolicited or unauthorized advertising, promotional materials, email, junk mail, spam, chain letters, or other form of solicitation through the LiquidTrust Technology.

• 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.

• 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.

• 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.

• Modify, translate, or otherwise create derivative works of any part of the LiquidTrust Technology or Content other than your own User Content.

• Interfere with, or attempt to interfere with, the access of any user, host, or network, or use any device, software, or routine that is intended to damage, surreptitiously intercept, or expropriate any system, data, or communication, including, without limitation, by sending a virus, overloading, flooding, spamming, or mail-bombing the LiquidTrust Technology.

• Collect from or store on the LiquidTrust Technology any personally identifiable information or protected health information of other users without their express permission.

• Impersonate or misrepresent your affiliation with any person or entity.

• Encourage, assist, allow, or enable others to do any of the foregoing.

3. Unacceptable Jurisdictions and Persons 

(a) Prohibited Jurisdictions – 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:

• Jurisdictions subject to comprehensive sanctions or embargoes by the U.S. Office of Foreign Assets Control (“OFAC”), including but not limited to Cuba, Iran, North Korea, Syria, Russia, the Crimea, Donetsk, and Luhansk Regions;

• Any jurisdiction identified on the Financial Action Task Force (“FATF”) 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-Specific Restrictions

You are prohibited from using the LiquidTrust Technology to directly or indirectly export, re-export, sell, or supply accounting, trust and corporate formation, management consulting services, architecture services, or engineering services to any person located in Russia. Further, you are prohibited from using the LiquidTrust Technology in connection with any goods prohibited by law (e.g., luxury goods) from Russia.

4. Unacceptable Activities

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.

5. Restricted Businesses

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. 

6. Security Violations & Network Abuse

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.

7. Monitoring and Enforcement

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 violation of this AUP or misuse of the LiquidTrust Technology. LiquidTrust may audit your compliance with this AUP upon reasonable notice, including by requesting transaction data, KYC records, and policies.

We may report any actual or suspected violations to law enforcement, regulators, or other appropriate third parties.

8. Suspension and Termination

8.1 LiquidTrust may suspend or terminate your access to the LiquidTrust Technology for AUP violations with or without notice to you.

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.

Appendix A
Definitions & References for Section 3

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.