High-risk activities must be disclosed
A high-risk activity is not automatically prohibited, but it requires complete disclosure and may require licensing, enhanced due diligence or written approval before access is granted.
- Money services, including remittances, ATMs, prepaid or gift-card programs and check cashing
- Lending, credit or banking services
- Foreign-exchange, virtual-currency brokerage or over-the-counter trading
- Holding or controlling client funds, including escrow arrangements
- Third-party payment processing or payment aggregation
