1. Purpose
This Customer Acceptance Policy ("Policy") sets out the principles and rules governing the onboarding and continued relationship with clients using virtual IBAN (vIBAN) services. The goal is to mitigate regulatory, compliance, and reputational risks by establishing clear criteria for client eligibility.
2. Prohibited countries
Clients with direct or indirect links to the following countries are strictly prohibited from being onboarded. This includes companies registered, operating, or having UBOs currently residing in or holding citizenship from these jurisdictions.
However, the place of birth or former citizenship alone shall not constitute a disqualifying factor, provided that the UBO holds a valid residence permit or citizenship in an eligible jurisdiction and passes enhanced due diligence.
– Abkhazia;
– Afghanistan;
– Albania;
– American Samoa;
– Bahamas;
– Barbados;
– Belarus;
– Botswana;
– Cambodia;
– Central African Republic;
– Cuba;
– Democratic Republic of the Congo;
– Ethiopia;
– Ghana;
– Haiti;
– Iran;
– Jamaica;
– Kashmir;
– Lebanon;
– Libya;
– Mali;
– Mauritania;
– Mongolia;
– Myanmar;
– Nagorno-Karabakh;
– Nicaragua;
– North Korea (Democratic People’s Republic of Korea, DPRK);
– Palestine;
– Russia;
– Samoa;
– Senegal;
– Serbia;
– Somalia;
– South Ossetia;
– South Sudan;
– Syria;
– Trinidad and Tobago;
– Uganda;
– Ukraine
– Crimea and Sevastopol (Crimea);
– Vanuatu;
– Zimbabwe;
– Donetsk People’s Republic (DNR);
– Luhansk People’s Republic (LNR)
In addition, KEYTOM does not engage with or present clients connected to any other jurisdictions subject to United Nations sanctions, OFAC sanctions, Canadian sanctions regimes, European Union sanctions, or other applicable international sanctions regimes.
3. High-risk jurisdictions
Additional countries classified as High Risk by FATF, the EU, or the UK may be subject to enhanced due diligence or rejection based on case-by-case assessment.
4. Prohibited industries
The following industries are prohibited regardless of licensing status:
Shell Structures and Non-Transparent Entities
– Shell banks and shell financial institutions
– Companies with no physical presence, no factual business address, or no connection to real economic activity
– Entities registered in jurisdictions with materially insufficient reporting or transparency obligations
– Companies issuing bearer shares
– Shell companies and fifth-party payment structures
– Downstream correspondent banking arrangements
Unlicensed or Illegal Financial Services
– Unlicensed forex brokers and foreign exchange intermediaries
– Binary options trading
– Unlicensed investment or investment ancillary services
– Hawala and other informal value transfer systems (HOSSP)
– Money orders and traveler’s cheques issuance
– Debt recovery services
– Cash collection services
Weapons, Military, and Security
– Arms, ammunition, and dual-use goods
– Military-grade security equipment and systems
– Manufacture of explosives, gunpowder, and ammunition
– Manufacture of military fighting vehicles
– Private military organizations or companies
Controlled, Regulated, and Hazardous Goods
– Production of precious metals and precious stones
– Processing of nuclear fuel or nuclear-related materials
– Unregulated pharmaceuticals
– Unregulated food supplements
– Legal and illegal substances, including medical marijuana, where such activities are identified as prohibited
Technology Abuse and Deceptive Practices
– Cyberlockers and anonymous file storage services
– IPTV and unauthorized streaming services
– No-value-added or deceptive resale services
– Get-rich-quick schemes
– Ponzi schemes and pyramid schemes
Other Prohibited Activities
– Unlicensed or unregulated charities
– Political or religious organizations with extremist affiliations
– Pawnshop services
– Detective services
– Unregulated auctions
– Used car dealerships
– Tobacco and alcohol distribution.
5. Special notes on corporate structures
A client may submit onboarding applications as part of a group of affiliated companies (e.g. MSB and VASP entities) that are under common control or ownership. In such cases, the group will be treated as a single client for the purpose of onboarding, provided this structure is clearly disclosed in writing.
Onboarding of multiple related entities for the purpose of regulatory circumvention (e.g. EU restrictions) is not permitted unless properly justified and transparent. The Company reserves the right to request supporting documentation regarding intra-group ownership and business justification.
6. Required documentation for onboarding
Corporate customers must provide:
1. Registration/Incorporation Details of Corporate Customer
2. Document details (Name/Surname/Document Number of UBO etc)
3. Address details
4. Information about ultimate Beneficial Owner/significant control over 25% / if UBO is a legal entity or a physical person
5. Ultimate Beneficial Owner(s) details
6. Other details - business activity description and any other relevant information (website etc.)
7. Description of customer’s business partner
8. Description of customer’s fund flow using Keytom services
9. Any adverse information about customer/related person/business partner
10. Compliance overall evaluation
11. Other details
7. Final Review
All customer applications will be reviewed by the compliance team. Applications may be approved, rejected, or returned with additional questions. No services will be provided until full due diligence is completed.
