Customer Acceptance Policy

This document established the amount of risk Eqwire UK Limited (hereinafter referred to as “the
Firm”, “the Company”, “eqwire”, “Eqwire UK”, “we”, “our”, or “us”) is willing to accept in the pursuit
of its business objectives and the criteria of non-acceptable and acceptable customers to whom we
provide our services.

During its operations, the Firm 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. Private individuals.

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

The Company 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.

The Company 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
shall be classified in the following Anti-Money Laundering (AML) risk categories:

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

The category of  “Unacceptable customers ” includes customers in one of the following situations:

  • 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;
  • 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;
  • Persons or entities indicted or convicted of money laundering, financing terrorism acts, fraud,
    theft, embezzlement, corruption, bribe, or tax evasion;
  • 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;
  • Shell companies;
  • Shell banks;
  • Persons and entities identified by the Compliance Function as posing an unacceptable risk level;
  • Private individuals and entities domiciled outside the UK or outside the EEA;
  • Individuals and entities who refuse to provide identification or other required information
    and documentation as required by the Firm or applicable legal requirements;
  • Individuals and entities under investigation for money laundering, financing terrorism acts,
    fraud, theft, embezzlement, corruption, bribe, or tax evasion;
  • Individuals and entities with whom the Firm terminated the business relationship;
  • Private individuals, and legal entities with a rejection risk score following an internal risk
  • Unregistered charities and non-profit organisations;
  • Companies identified with unauthorised activity;
  • Persons and entities who do not pass the Firm’s due diligence checks or Know Your Customer
    periodic refreshes;
  • Illegal immigrants; and
  • 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 of prohibited risk. eqwire does not
offer services to clients in these categories and does not have a risk appetite for it.

  • Cash based businesses
  • Online gambling
  • Adult entertainment
  • Unregulated entities conducting activities that require regulations
  • Cryptoasset businesses

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. Such cases are subject to review and pre-approval by
the Compliance Function and acceptance by the acceptance Executive Risk & Compliance Committee,
as with all high-risk businesses, as well as being subject to review and acceptance from relevant
banking partners where required.

The category of “High-risk business and customers” includes businesses and customers in one of the
following situations:

  • 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;
  • Entities whose headquarters or whose direct, indirect or beneficial owner is located in high-
    risk countries and territories;
  • Private individuals whose nationality or residency is in high-risk countries and territories;
  • Entities identified by the Compliance Function as posing a high-risk level during the process of onboarding and due diligence;
  • Customers who have been assessed as high risk following the Firm’s risk assessment;
  • Individuals indicted or convicted for non-economic or non-financial crimes;
  • 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;
  • 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 is not exhaustive
and is reviewed on a quarterly basis.

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

Applications from such businesses are referred to the manual process for deeper review, a pre-
approval from the Compliance Function and approval by the Executive Risk & Compliance Committee
as to whether they are acceptable or not on a case-by-case basis.

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

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

The category of “Medium risk customers” includes customers who do not fall under other risk categories.

The category of “Low-risk customers” 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

We are focused on attracting and servicing customers in the UK and the EU 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 UK Limited will 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.