Customer Acceptance & Eligibility Policy

During its operations, eqwire aims at attracting customers within its business activities, according to its internal segmentation, as follows:

1. Legal entities;
2. Other legal entities (including financial institutions, banks); and
3. Individuals.

eqwire offers to the accepted customers its products and services in their respective segments.

eqwire does not accept as a customer and does not perform transactions with, even if occasionally, nominated entities which have been or still are under the restraint of international sanctions of funds blockage.

eqwire does not perform transactions involving goods or services contrary to legislation regarding international sanctions of funds blockage and embargoes.

According to their associated risks, during the process of onboarding and due diligence, the customers are classified in the following risk categories:

1. Unacceptable customers;
2. High risk customers;
3. Medium risk business customers;
4. Low risk business customers.

eqwire does not accept as a customer from the following category of Unacceptable Customers and Unacceptable Businesses:

1. Designated persons and entities according to the legislation regarding international or country-specific sanctions of funds blockage of the UN, UK HMT, EU and US OFAC;
2. Entities of which the headquarters or country of activity is in the list of countries under international or country-specific comprehensive sanctions of trade embargo of the UN, UK HMT, EU and US OFAC;
3. Persons or entities indicted or convicted of money laundering, financing terrorism acts, fraud, theft, embezzlement, corruption, bribe, or tax evasion;
4. Persons and entities who are listed or included in Public Notices of the Governments and regulatory authorities of countries for breach of regulatory requirements, money laundering, financing terrorism acts, fraud, theft, embezzlement, corruption, bribe, or tax evasion;
5. Shell companies;
6. Shell banks;
7. Persons and entities identified by the Compliance Function as posing an unacceptable risk level;
8. Private individuals and entities domiciled outside the UK or outside the EEA;
9. Individuals and entities who refuse to provide identification or other required information and documentation as required by the Firm or applicable legal requirements;
10. Individuals and entities under investigation for money laundering, financing terrorism acts, fraud, theft, embezzlement, corruption, bribe, or tax evasion;
11. Individuals and entities with whom the Firm terminated the business relationship;
12. Private individuals, and legal entities with a rejection risk score following an internal risk assessment;
13. Unregistered charities and non-profit organisations;
14. Companies identified with unauthorised activity;
15. Persons and entities who do not pass the Firm’s due diligence checks or Know Your Customer periodic refreshes;
16. Illegal immigrants; and
17. Individuals or entities subject to civil recovery proceedings or judgments.

Unacceptable Businesses

The following is a list of business activities that we consider to be unacceptably high-risk. eqwire does not offer services to clients in these categories and does not have a risk appetite for them.

• Cash-based businesses
• Online gambling
• Adult entertainment
• Unregulated entities conducting activities that require regulations
• Weaponry industry
• Chemical, biological, nuclear or radiological sector
• Heavy industry which severely impacts the environment, such as the coal industry etc.
• Trusts*
• Cryptoasset businesses in the UK

*Regarding Trusts, in particular, these are assumed to be unacceptably high risk (including where a Trust is included in the beneficial ownership structure of a client) unless a clear rationale for the existence of the trust can be obtained, along with acceptable documentation providing complete clarity of the individuals involved in the trust.

eqwire accepts High-Risk Customers and High-Risk Businesses which fall under the following criteria depending on the outcome of the Enhanced Due Diligence in regard to this customer category. Eqwire reserves the right not to onboard a High-Risk Customer should the eqwire’s request for information/documentation not be satisfied or the risk assessment should show a level of risk beyond eqwire’s risk appetite.

1. Entities owned directly, indirectly or whose beneficial owners are persons identified as a PEP (politically exposed person) resident in another member state of the EU or of the EEA or in a third party state;
2. Entities whose headquarters or whose direct, indirect or beneficial owner is located in high-risk countries and territories;
3. Private individuals whose nationality or residency is in high-risk countries and territories;
4. Entities identified by the Compliance Function as posing a high-risk level during the process of onboarding and due diligence;
5. Customers who have been assessed as high risk following the eqwire’s risk assessment;
6. Individuals indicted or convicted for non-economic or non-financial crimes;
7. Customers whose name is found in adverse media and confirmed with a positive match for any other adverse event than money laundering, financing terrorism acts, fraud, theft, embezzlement, corruption, bribe, or tax evasion;
8. Dormant companies, or companies which were dormant for a period of >1 year.

High-Risk Businesses

The following is a list of business activities that we consider to be high-risk. The list might be not exhaustive and is reviewed by eqwire regularly.

• Financial Services & Fintech Firms*
• Cryptoasset Businesses in the EU**
• Subsidiary businesses where we need to follow a chain including through businesses registered outside of the UK to reach beneficial owners.
• Unregistered charities
• Defence and aerospace (excluding weaponry)
• Clients linked with Politically Exposed Persons (PEPs).
• Clients linked to adverse press
• Trusts***
• Accountancy Service Providers (ASPs)
• Payroll & Employment Service Providers
• Travel Companies
• Gambling (excluding online gambling)

* Regarding Financial Services and Financial Technology businesses, the following are examples of sub-sectors which would be of an acceptable risk level, though of high risk, and each business would still be subject to individual and manual review:

• Pay day lending businesses
• Invoice finance businesses
• Crowd funding businesses
• International remittance businesses
• Bureau de change businesses

**For the EU market, the cryptoasset businesses licensed in the EU will be introduced to Modulr FS Europe Limited, and Modulr FS Europe Limited will discharge the end-to-end compliance requirements. eqwire’s role will be of a distributor/agent and introducer only.

***Regarding Trusts, in particular, these are assumed to be unacceptably high risk (including where a Trust is included in the beneficial ownership structure of a client) unless a clear rationale for the existence of the trust can be obtained, along with acceptable documentation providing complete clarity of the individuals involved in the trust.

eqwire accepts Medium Risk Customers with a Standard Due Diligence. This category includes customers who do not fall under other risk categories.

eqwire accepts Low-risk Customers, a category that includes customers in one of the following situations:

1. Companies whose securities are traded on a regulated market in the UK, US or one of the EU member states and companies listed on a market of third states and which are submitted to reporting and transparency requirements equivalent to EU Community legislation;
2. Public authorities/institutions, central and local, from the UK or EU.

Geographic Location

eqwire is focused on attracting and servicing customers in the UK and the EEA for the foreseeable future, which reduces the risk. eqwire has no association with or processes transactions to the following sanctioned countries:

• Cuba
• Iran
• Iraq
• Yemen
• Afghanistan
• North Korea
• Syria
• Myanmar (previously Burma)
• Ivory Coast (Cote D’Ivoire)
• Venezuela
• Russia
• Belarus
• Crimea
• Libya
• Palestinian Territory
• South Sudan
• Antarctica

eqwire not enter into a business relationship with any client domiciled outside the EEA and will not execute any transaction of the users domiciled in a country which is listed as prohibited within our country risk assessment.