Approach
Halfin prohibits use of the Services for activities that are unlawful in relevant jurisdictions, that present unacceptable AML, sanctions, fraud, reputational, or operational risk, or that are inconsistent with Halfin's commercial scope.
Halfin reserves the right to determine, in its sole discretion, whether an activity is prohibited and to take any measure it considers appropriate, including suspension or termination of access, freezing of pending transactions, and reporting to authorities.
Prohibited activities
The categories below describe activities for which Halfin does not provide Services.
Financial crime and sanctions evasion
- Money laundering, terrorism financing, proliferation financing, and any activity in support of such conduct.
- Sanctions evasion, including transactions involving sanctioned individuals, entities, vessels, aircraft, or jurisdictions.
- Use of coin tumblers, mixers, anonymizing services, or privacy-enhancing tokens (including Monero and shielded Zcash) to obscure fund flows.
- Operating an unregistered or unlicensed money service business, exchange, broker-dealer, or other regulated financial institution where licensing is required.
- Transactions structured to evade reporting thresholds or compliance controls.
Fraud and deception
- Ponzi, pyramid, multi-level marketing schemes, high-yield investment programs, and similar arrangements.
- Market manipulation, including spoofing, wash trading, pump-and-dump, and similar conduct.
- Impersonation, submission of false or stolen KYC documents, or any deceptive identity practice.
- Phishing, social engineering, account takeover, credential stuffing, and similar attacks.
- Creating multiple accounts to circumvent restrictions or abuse referral, promotional, or fee structures.
Unauthorized financial services
- Unlicensed securities offerings (including ICOs, IEOs, IDOs) where licensing is required.
- Unauthorized lending, escrow, insurance, brokerage, custody, or similar regulated activities.
- Unauthorized investment advisory services.
- Use of the Services as a custodial wallet substitute or to provide custodial services to third parties.
Illegal goods and services
- Distribution of controlled drugs, prescription medications, narcotic precursors, or instructions for their manufacture.
- Sale of weapons, ammunition, explosives, military or dual-use goods where prohibited by law.
- Counterfeit goods, including currency, identity documents, and branded merchandise.
- Stolen goods or goods of unverified provenance, including cultural heritage items.
- Endangered species, ivory, and protected wildlife products.
- Human organs, human remains, and unlawful biological materials.
- Materials promoting violence, terrorism, or self-harm.
- Child sexual abuse material and any content sexualizing minors.
- Non-consensual intimate imagery.
- Materials inciting hatred, discrimination, or violence against protected groups.
Cybercrime
- Malware, ransomware, spyware, exploit kits, and tools designed primarily for unauthorized access.
- Sale or distribution of hacking services, including DDoS-for-hire.
- Sale of compromised credentials, personal data, or other materials obtained through unlawful means.
- Tools designed to bypass technical protection measures, regional restrictions, or copyright protections.
Adult content with specific restrictions
Adult content is permitted only where it complies with applicable law in all relevant jurisdictions and does not involve:
- Performers below the age of 18.
- Non-consensual material.
- Trafficking, prostitution, or unlawful escort services.
- Content depicting violence, abuse, or harm.
Gambling and games of chance
Online gambling and games of chance are permitted only where the Merchant holds a valid license in each jurisdiction in which it offers services, and the Services are not used to accept payments from End-Users in jurisdictions where the Merchant is not licensed. Unlicensed gambling is prohibited.
Other prohibited categories
- Cash-intensive businesses that do not maintain adequate AML controls.
- Shell companies without verifiable beneficial ownership or business purpose.
- Adult entertainment services that violate applicable law.
- Sale of police, military, or government-issued items or uniforms where prohibited.
- Sale of awards, decorations, or distinguishing badges of national governments.
- Sale or distribution of state, banking, or trade secrets.
- Spam list distribution, scraped personal data sales, and similar privacy violations.
- Trading of items where serial numbers or identifying marks have been removed.
- Pyrotechnic, incendiary, and radioactive materials outside lawful trade.
- Services to military entities engaged in active hostilities or under sanctions.
Permitted but high-attention verticals
The following verticals are permitted but subject to enhanced due diligence and ongoing monitoring:
- iGaming and online gambling, with valid licensing in each operating jurisdiction.
- FX brokers and money services, with appropriate regulatory status where required.
- Affiliate marketing networks, with documented payout flows and counterparty diligence.
- E-commerce and marketplaces, including cross-border merchants.
- EdTech, including global tuition collection and contractor payouts.
- High-risk consumer subscription services.
Application
Halfin determines whether a Merchant's activity is permitted based on the totality of available information, including KYB-declared business model, transaction patterns, counterparty profile, public-facing materials, and regulatory environment.
Use of the Services for any prohibited activity will result in suspension or termination of access, possible freezing of pending transactions, and where appropriate, reporting to law enforcement, financial intelligence units, or other competent authorities.
Merchants must:
- Disclose all relevant business activities at KYB and update disclosures when activities change.
- Operate only within the scope approved during onboarding.
- Maintain licensing and regulatory status applicable to their activities.
- Not facilitate prohibited activities by their End-Users or counterparties.
Updates
This list is reviewed periodically and may be updated based on:
- Changes in applicable law and sanctions regimes.
- Emerging risk patterns.
- Regulatory expectations.
- Halfin's internal risk assessment.
Change authority
Halfin may add or remove categories at any time without prior notice.