Acceptable Use Policy

This Acceptable Use Policy (“AUP”) describes the baseline rules, restrictions, and expectations that apply to access to and use of Axente Swiss GmbH’s website, platform, onboarding channels, and related services.

This AUP should be read together with our Terms of Use, Risk Disclosure, Privacy Policy, Cookies Policy, and any separate contractual documentation made available to clients or prospective clients.

This AUP explains the types of use that are prohibited, unsupported, restricted, or subject to enhanced review, approval, or additional documentation.

This AUP is intended to promote lawful use, platform integrity, compliance with applicable laws and regulations, and the protection of Axente, its clients, Partner Providers, and the wider financial system.

This AUP applies, as relevant, to:

• visitors to the Axente website;

• persons contacting Axente or submitting inquiries;

• prospective clients during pre-onboarding or onboarding;

• clients and authorised users using Axente’s platform, accounts, payment functionality, merchant services, FX, or digital asset-related services; and

• any person interacting with Axente through APIs, technical integrations, dashboards, or partner-supported environments.

You may use Axente’s website and services only for lawful business purposes and only in a manner consistent with:

• applicable laws and regulations;

• anti-money laundering, counter-terrorist financing, sanctions, and fraud-prevention requirements;

• Axente’s internal compliance and risk policies;

• Partner Provider requirements; and

• any separate contractual documentation or onboarding conditions.

Axente generally supports permanent business relationships only and may decline one-off, ad hoc, or unsupported relationship structures where inconsistent with its AML framework, risk appetite, or Partner Provider requirements.

4.1 Illegal Activity

Any unlawful activity, including conduct prohibited by Swiss law, applicable foreign law, sanctions laws, AML/CTF requirements, fraud laws, consumer laws, intellectual property laws, or data protection laws.

4.2 Sanctions Evasion and Restricted Counterparties

Any activity involving sanctioned persons, sanctioned countries, blocked parties, embargoed sectors, sanctions evasion structures, or attempts to conceal or circumvent sanctions controls.

4.3 Money Laundering, Terrorist Financing, or Criminal Proceeds

Any activity involving disguised ownership, unexplained funds flows, structuring, layering, rapid pass-through activity without legitimate rationale, shell arrangements used abusively, or any activity linked to criminal property or terrorist financing.

4.4 Fraud, Deception, Misrepresentation, or Abuse

Fraud, scams, phishing, impersonation, forged documents, false statements, manipulated invoices, fake merchants, fake transactions, sham counterparties, synthetic identities, or deceptive commercial conduct.

4.5 Unauthorised or Prohibited Financial Activity

Unlicensed financial services, unlawful payments activity, prohibited money transmission, prohibited exchange activity, prohibited investment or securities activity, or any regulated activity carried out without the necessary permissions or approvals.

4.6 Illegal Goods or Services

Transactions, websites, businesses, or payment flows involving illegal goods, illegal services, or unlawful content.

4.7 Misuse of Personal Data or Technology

Misuse of personal data, unauthorised tracking, cyber abuse, malware, credential theft, hacking attempts, API abuse, or any attempt to compromise systems, security, data, or infrastructure.

4.8 Circumvention of Controls

Any attempt to circumvent Axente’s compliance, risk, onboarding, transaction monitoring, wallet verification, screening, reserve, sanctions, or whitelisting controls, including the use of intermediaries, nested structures, undisclosed third parties, nominee arrangements, or misleading payment narratives.

Axente does not support or accept the following, unless expressly stated otherwise in writing and permitted under the applicable legal and contractual framework:

• physical cash, coins, or other physical items of value;

• public deposits at Axente level;

• pseudonym or numbered mandates;

• joint mandates;

• power-of-attorney holders on a mandate where unsupported under Axente’s onboarding framework; and

• other service types or operational arrangements outside Axente’s stated service model, risk appetite, or Partner Provider requirements.

Unless expressly agreed otherwise in writing, Axente does not provide custody of digital assets. Use of digital asset-related services is subject to wallet verification, Travel Rule, compliance, and Partner Provider requirements.

Axente does not support, onboard, or provide services to businesses active in the following prohibited or unsupported sectors:

• defence industry, including aircraft, spare parts, technology, fuel, vehicles, and dual-use goods;

• military, weapons, or arms;

• energy commodities, including oil and gas;

• pharmaceuticals;

• precious stones, gemstones, diamonds, and precious metals;

• trading in cannabis, alcohol, and/or tobacco;

• cash-related businesses, including businesses involving large-scale cash transactions;

• offline erotic or adult entertainment;

• exotic animals;

• charity, NGO, or non-profit organisations;

• art and antiques; and

• commodities trading.

Axente may reject, suspend, or terminate any relationship connected with these sectors at its discretion and in accordance with applicable law, its internal policies, and Partner Provider requirements.

Some sectors may be subject to enhanced due diligence, specific written approval, additional controls, transaction limits, Partner Provider restrictions, or later withdrawal of support.

These include, in particular:

• cryptocurrency / DLT businesses;

• gambling and sports-related businesses; and

• regulated financial institutions.

Axente may also classify other sectors or business models as restricted or enhanced-risk depending on the specific service, jurisdiction, transaction profile, delivery channel, or Partner Provider requirements.

Axente does not onboard customers domiciled in, operating from, or carrying on current business activity in unsupported jurisdictions. Axente also does not execute transactions to such jurisdictions or accept transactions originating from such jurisdictions.

As of the date of this AUP, unsupported jurisdictions include:

• Belarus;

• Burundi;

• Central African Republic;

• Congo, Democratic Republic;

• Guinea;

• Guinea Bissau;

• Iran;

• Lebanon;

• Libya;

• Mali;

• Myanmar;

• Nicaragua;

• Democratic People’s Republic of Korea;

• Russia;

• Somalia;

• Sudan;

• South Sudan;

• Syria;

• Venezuela;

• Yemen;

• Zimbabwe;

• Ukraine, occupied areas; and

• Ukraine, non-occupied areas.

In addition, customers domiciled in the United States of America, its territories, or otherwise taxable in the United States are not accepted.

Axente may update the list of unsupported jurisdictions from time to time in accordance with applicable law, sanctions requirements, internal policy, and Partner Provider restrictions.

Axente may also decline, refuse to onboard, or terminate relationships involving categories that are not supported under its AML framework, including:

• shell banks or banks without a physical presence in the place of incorporation;

• domiciliary companies;

• associations;

• trusts;

• foundations;

• insurance wrappers or similar structures;

• escrow structures; and

• politically exposed persons (PEPs), where prohibited under Axente’s current AML framework.

Axente also does not support pseudonym or numbered mandates, joint mandates, or power-of-attorney holders on a mandate, unless expressly stated otherwise in writing.

Many Axente services rely on Partner Providers such as banks, payment institutions, acquirers, liquidity providers, compliance vendors, and digital asset infrastructure providers.

As a result, use of Axente services may also be subject to:

• Partner Provider onboarding standards;

• transaction or settlement restrictions;

• account ownership rules;

• wallet verification rules;

• reserve or collateral requirements;

• acquirer or scheme rules;

• supported-asset restrictions; and

• corridor or jurisdiction limitations.

A service may be restricted or declined even if a business activity is lawful in principle, where such activity is inconsistent with Partner Provider requirements or Axente’s risk appetite.

You must provide accurate, complete, up-to-date, and not misleading information at all times.

Axente may require:

• identification documents;

• corporate records;

• ownership and control information;

• source-of-funds or source-of-wealth evidence;

• website, product, or business model information;

• contracts, invoices, or supporting records;

• wallet ownership proof;

• counterparty information; and

• any other information reasonably required for compliance, fraud prevention, security, legal, or operational reasons.

Failure to provide sufficient information may result in delays, rejection, suspension, restrictions, or termination.

Axente may monitor use of its website and services for compliance, security, fraud-prevention, legal, and operational purposes.

Where appropriate, Axente may:

• request additional information;

• impose limits or reserves;

• reject, delay, return, or block transactions;

• restrict products, features, jurisdictions, or counterparties;

• suspend or terminate access;

• decline onboarding or continued service; and

• file legally required reports or notifications with competent authorities or other legally relevant bodies.

Axente is not required to approve or continue any relationship where the risk is not acceptable.

This public AUP is a general website-level statement.

Where a client relationship exists, more specific contractual terms, onboarding conditions, service-specific schedules, compliance notices, or Partner Provider rules may apply in addition to this AUP and may override or supplement it.

Axente may update this AUP from time to time.

The current version published on the Website is the relevant public version unless separate contractual documentation provides otherwise.