Acceptable Use Policy

1. Scope

This Acceptable Use Policy (“AUP”) describes activities and business categories that are prohibited or restricted on the Kliro platform. It reflects (i) the operating rules of Visa, Mastercard, American Express, and Discover, (ii) US anti-money-laundering and counter-financing-of-terrorism (“AML/CFT”) laws administered by FinCEN, (iii) sanctions programs administered by the Office of Foreign Assets Control (“OFAC”), and (iv) other applicable federal and state law. Violation of the AUP may result in immediate suspension, fund hold, contract termination, recovery of losses, and reporting to law enforcement and regulators.

2. Prohibited Activities

Customer may not use the Services to engage in or facilitate:

• Money laundering, structuring, or terrorist financing;
• Tax evasion or fraud against any tax authority;
• Transactions involving illegal drugs or controlled substances (other than properly licensed pharmaceuticals where allowed);
• Trafficking in firearms, ammunition, explosives, or weapons of war;
• Human trafficking, forced labor, or commercial sexual services;
• Sale or distribution of child sexual abuse material;
• Intellectual-property infringement, counterfeiting, or piracy;
• Transactions with sanctioned persons, entities, or jurisdictions designated by OFAC, the UN, the EU, or comparable bodies;
• Any activity that violates applicable US federal, state, or local law.

3. Prohibited Business Categories

Without limiting Section 2, Kliro does not support the following business categories under any plan:

• Adult content and escort services, including pornographic websites and dating sites with explicit content;
• Unlicensed gambling, lotteries, sweepstakes, or skill-gaming-for-money;
• Unregistered financial services, including unlicensed money-services businesses and unregistered investment platforms;
• Cryptocurrency exchange and custody services without prior approval and enhanced KYB (see Section 4);
• Alcohol sales without age verification and required licensing;
• Cannabis, CBD, and related products sold without applicable state and federal licensing and age verification;
• Prescription pharmaceuticals sold without proper licensing and prescription verification;
• Tobacco, vaping, and e-cigarette products without age verification;
• Firearms, ammunition, explosives, and accessories that bypass federal background-check requirements;
• Tools designed to circumvent digital-rights management (“DRM”) or copy-protection;
• Trade in endangered species or products thereof in violation of CITES;
• Multi-level marketing or pyramid schemes that offer guaranteed returns, Ponzi schemes, and chain-letter solicitations;
• “Miracle” health products, unsubstantiated cures, and deceptive supplements;
• Hate speech, doxxing platforms, harassment-for-hire services, and content advocating violence;
• Spyware, stalkerware, credential stuffers, and similar offensive software;
• Shell-company services, anonymous mailing addresses for evasion, and document-forgery services.

4. High-Risk Categories Requiring Enhanced Due Diligence

The following categories may be supported subject to (i) enhanced KYB review, (ii) increased rolling reserves, and (iii) custom pricing reflecting risk profile:

• Long-haul travel, ticketing, and tour operators;
• Subscription-continuity offers and free-to-paid trial conversions;
• Online coaching, training, and information-product businesses;
• Crowdfunding, donation platforms, and not-for-profit fundraising;
• Multi-vendor marketplaces and creator-economy platforms;
• Licensed cryptocurrency exchanges, custodians, and on/off-ramp services;
• High-chargeback verticals (digital goods with high refund rates, dating services, telehealth-adjacent businesses).

5. Platform-Behavior Rules

Customer agrees not to:

• Open or operate multiple accounts to circumvent risk limits or evade enforcement actions;
• Misuse or abuse the API, including scraping, rate-limit evasion, fingerprint spoofing, or distributed denial-of-service attacks;
• Distribute malware, viruses, ransomware, or any malicious code through the Services;
• Engage in card testing or systematic small-amount transactions designed to validate stolen card numbers;
• Manipulate fraud signals, identity-verification flows, 3-D Secure outcomes, or analytics data;
• Process payments on behalf of a third party (“factoring”) without written consent, including aggregating payments for an unverified merchant;
• Use the Services to test, probe, or compromise the security of any system, network, or account;
• Use the Services in connection with any business activity outside the scope of Customer's approved business profile on file with Kliro.

6. Reporting Abuse

To report suspected abuse, fraud, account takeover, or violations of this AUP, contact abuse@kliro.io. Reports are reviewed by Kliro's Trust & Safety team and acknowledged within two (2) business days.

7. Enforcement

Kliro reserves the right, in its sole discretion, to take any of the following actions in response to a suspected or confirmed violation of this AUP:

• Issue a written warning;
• Limit transaction volume, payment methods, or geographic acceptance;
• Suspend the account pending investigation;
• Place a hold on funds and apply or increase a rolling reserve;
• Terminate the Agreement and permanently close the account;
• Forfeit disputed amounts to cover chargebacks, fines, or losses;
• Report the activity to FinCEN, OFAC, the Federal Bureau of Investigation, state attorneys general, and other competent authorities;
• Pursue civil or criminal remedies, including injunctive relief and recovery of damages and attorneys' fees.

Decisions taken under this AUP are final at Kliro's sole discretion, subject only to any right of appeal expressly granted in the applicable Order Form.