APPENDIX NO. 5c TO THE REGULATION - LIST OF HIGH RISK SELLERS

I. HIGH RISK INDUSTRIES

(1) The following are considered to be high risk industries:

a. 8699 – Crowdfunding 

b. 8398 / 8641 - Foundations, donations or third party collected funds 

c. 6300 - Insurance services

d. 6051 - Debt recovery and vindication 

e. 8651 - Political related payments (donations for a political party) 

f. 8661 - Legal religious organizations 

g. 6012 - Loans and credit institutions 

h. 5933 - Pawnshops 

i. 6211 – Regulated Forex brokers licensed in EEA countries

j. Multi-level marketing businesses 

 

(2) In relation to Sellers from one or more of the industries referred to in clause I.1 above, the Provider is entitled to:

a. to approve card Payments

b. to carry out additional checks.

 

II. OTHER HIGH RISK VERTICALS - DUE TO MONEY LAUNDERING/TERROR FINANCING RISK

(1) The following are considered to be high-risk sectors due to money laundering and terrorist financing risks: 

a. 5094 - Wholesale distributors of jewelry, timepieces, precious stones, and metals

b. 5944 - Jewelry 

c. 5300 - Wholesale clubs 

d. 7278 - Luxury goods - buying/shopping clubs 

e. 5932 - Antiques 

f. 5971 - Art dealers a galleries 

g. 5972 - Stamps a coins collecting

h. 5533 - Moto a automobile parts 

i. 5013 - Wholesale distributors of motor vehicle accessories, tools, equipment, and new parts

(2) In relation to Sellers from one or more of the industries referred to in clause I.1 above, the Provider is entitled to:

a. to approve card Payments,

b. to carry out additional checks.

 

III. OTHER CRITERIA INDICATING A HIGH RISK OF MONEY LAUNDERING AND TERRORIST FINANCING

(1) A high risk of money laundering and terrorist financing may be attributed to the Seller in particular for the following reasons: 

a. The Sellers, their representatives or the UBO (Ultimate Beneficial Owner) have a PEP (Politically Exposed Person) status,

b. The Sellers are linked to high-risk countries for money laundering and terrorist financing (through the nationality or country of residence of the representatives or UBOs, entities from the ownership structure registered in high-risk countries, etc.),

c. the ownership structure of the Seller appears unusual or overly complex given the nature of the Seller´s business,

d. the business model is not clear or may be used to make Payments related to politics (donations to a political party).

 

(2) The Seller acknowledges that the Provider:

a. does not enter into business relationships with entities registered in High Risk Countries, as defined by the European Commission, in accordance with Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purpose of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC ("High Risk Countries"),

b. does not process Payments related to High Risk Countries,

c. does not establish business relationships and does not process Payments related to Sanctioned Countries, in particular: Cuba, Iran, North Korea, Sudan and Syria,

d. does not establish relationship with sanctioned entities.