nsave Prohibitions List
Effective Date: July 3, 2026
1. Introduction
npay Inc. and npay USA Inc. (together, “npay”, “nsave”, “we”, “us”, or “our”) are committed to upholding the highest standards of compliance, safety, and integrity across our financial services. We operate in accordance with all applicable U.S. laws and regulations, including the Bank Secrecy Act, the USA PATRIOT Act, and the economic and trade sanctions administered and enforced by the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury. We also apply UK, EU, and UN sanctions across our business activities.
Part 1 – General Prohibitions (All Products and Services)
2. Prohibited Countries
We do not provide products and services to individuals or businesses resident in, incorporated in, or operating in the countries and regions listed below, and we do not allow customers to transact with counterparties located in them:
- Afghanistan
- Belarus
- Central African Republic
- Crimea
- Cuba
- Democratic Republic of the Congo
- Eritrea
- Iran
- Iraq
- Libya
- Mali
- Myanmar
- North Korea
- Russia
- Somalia
- South Sudan
- Sudan
- Ukraine (incl. the Kherson, Luhansk, Donetsk, and Zaporizhzhia regions)
- Venezuela
- Yemen
3. Prohibited Customers
We do not enter into or continue business relationships or transactions with:
- Individuals or entities subject to sanctions imposed by the UK, EU, UN, or US, or under the sanctions laws of any jurisdiction in which we operate;
- Individuals or entities engaging in activities that require a sanctions license without possessing or seeking such authorization;
- Entities or group companies which conduct material business activities (exceeding 5% of revenue) or maintain material customer bases (exceeding 5%) in sanctioned countries, territories, or regions;
- Customers who do not successfully complete our identity verification and due diligence checks;
- Customers connected to illegal or unlawful activities;
- Shell banks and banking institutions operating exclusively under offshore licensing arrangements;
- Financial institutions and jurisdictions designated under Section 311 of the USA PATRIOT Act;
- Bearer share companies (operating as such), excluding publicly traded entities on recognized exchanges.
4. Prohibited Activities
We do not provide products and services to individuals or businesses engaging in the activities below, and we do not allow customers to transact in connection with them:
- Activities which are or may be in breach of applicable laws, rules, or regulations;
- Activities related to human trafficking, modern slavery, or child exploitation;
- Adult services, including escort services and massage parlors;
- Drugs, including controlled substances and paraphernalia, and other products that present a risk to consumer safety, such as raw materials, chemicals, and psychoactive products;
- Illegal gambling, including arcades, betting, bingo, casinos, gambling software, and lotteries;
- Illegal or unlicensed financial services, including unregistered money services businesses, unlicensed money transmitters, unregulated trading platforms, unregulated foreign exchange services, currency circumvention, and unlicensed securities or investment activities;
- Unlicensed or illicit virtual-asset activity, including unlicensed or unregistered virtual currency brokers, exchanges, or money transmitters, and stored-value virtual currencies issued or operated without authorization;
- Illegal wildlife trade and environmentally harmful activities;
- Weapons, including firearms, ammunition and explosives, military and dual-use goods, software, and technologies, and fireworks.
5. Restricted Activities
The activities below are supported only in limited circumstances and are subject to enhanced due diligence and prior approval. If your activity falls into one of these categories, we may request additional information and documentation before providing or continuing services:
- Adult entertainment (including adult and dating websites);
- Cash-intensive services;
- Charities and non-profit organizations;
- Crowdfunding platforms;
- Debt collection;
- Extractive industries (such as metals, mining, oil, and gas);
- Freeports and free trade zones;
- High-value dealers (such as art dealers);
- Licensed gambling;
- Money transfer service businesses;
- Professional football (soccer);
- Trade finance and export finance facilities.
Part 2 – Card Program Prohibitions (Card Products Only)
The prohibitions and restrictions in this Part 2 apply only to nsave card products, including cardholders and card transactions. They are set by our card issuing partner and apply in addition to, and not in place of, the general prohibitions in Part 1. Where Part 1 and Part 2 differ, the stricter standard applies to card products.
6. Cardholder Prohibitions
Cards cannot be issued to any person resident in, incorporated in, or operating in:
Afghanistan; Belarus; Central African Republic; Cuba; Democratic Republic of the Congo; Eritrea; Iran; Iraq; Libya; Mali; Myanmar (Burma); Nicaragua; North Korea (DPRK); Russia; Somalia; South Sudan; Sudan; Syria; the Crimea, Donetsk, Luhansk, Kherson, and Zaporizhzhia regions of Ukraine; Venezuela; and Yemen.
Additional restricted jurisdictions.
Card applications from the following jurisdictions are subject to enhanced review and case-by-case approval, and may be declined at nsave’s sole discretion: China (Mainland), India, Israel, Nepal, Turkey, and Vietnam. Applications from countries appearing on international watchlists (for example, the FATF list of jurisdictions under increased monitoring) also require case-by-case review and approval.
Cards cannot be issued to businesses engaged in any of the following:
- Illegal or unlawful activities, or activities that are or may be in breach of applicable laws, rules, or regulations, including: distribution of illegal substances or controlled drugs without proper licensing; human trafficking, modern slavery, child exploitation, prostitution, or escort services; sale of counterfeit or unauthorized goods or intellectual property infringement; pyramid schemes, Ponzi schemes, multi-level marketing, or other deceptive or fraudulent practices; and production or distribution of illegal digital content;
- Weapons, arms dealing or manufacturing, firearms, ammunition, munitions, military goods, explosives, fireworks, or dual-use goods and technologies;
- Illegal gambling operations (including arcades, betting, bingo, casinos, gambling software, and lotteries);
- Illegal or unlicensed financial services, including unregistered money services businesses, unlicensed money transmitters, unregulated trading or foreign exchange platforms, currency circumvention, and unlicensed securities or investment activities;
- Shell banks and banking institutions operating exclusively under offshore licensing arrangements;
- Unlicensed virtual currency brokers, stored-value virtual currencies, and non-fungible tokens (NFTs), excluding regulated stablecoin activity;
- Illegal wildlife trade or activities harmful to the environment;
- Political campaign fundraising or donation platforms.
Restricted business models.
The following business models require documented licensing, enhanced due diligence, and prior approval before a card can be issued: money services businesses, money transfer businesses, and remittance services; cryptocurrency platforms and exchanges; charities, non-profit organizations, and NGOs; precious metals dealers and other high-value dealers; online content or creator platforms; licensed and regulated gambling or fantasy sports operators; adult entertainment; cash-intensive businesses; crowdfunding platforms; debt collection; extractive industries; freeports and free trade zones; professional football (soccer) organizations; and trade finance and export finance facilities.
7. Card Spending Prohibitions
Prohibited spending jurisdictions.
nsave cards cannot be used for spending in, or for transactions involving counterparties located in: Cuba; Iran; North Korea (DPRK); Russia; Syria; Venezuela; and the Crimea, Donetsk, Luhansk, Kherson, and Zaporizhzhia regions of Ukraine.
Prohibited purchase types – cards cannot be used for any of the following:
- Purchase or trade of digital or virtual currencies;
- Drug-related purchases, including marijuana, cannabis, CBD, controlled substances, drug paraphernalia, and black-market items;
- Purchases on dark web marketplaces, or payments for hacking, cybercrime, or theft-related services;
- Unlicensed internet pharmacies, or pharmacies operating outside regulated jurisdictions;
- Firearms, ammunition, munitions, explosives, fireworks, or military goods;
- Hazardous or poisonous materials and chemicals without proper regulatory clearance;
- Escort services, adult services, or similar platforms;
- Unlicensed or illegal auction sites;
- Unregulated lending, predatory lending, payday loan, or abusive debt-related services;
- Deceptive credit repair services;
- Data brokerage services, particularly those involving unauthorized personal data;
- Espionage equipment, signal jammers, or blockers;
- Purchase or trade of endangered species, protected wildlife, or wildlife products;
- Trade in human remains or body parts;
- Unlicensed or illegal gambling and betting;
- Materials or activities promoting intolerance, violence, or hatred.
8. Sanctions Screening
We screen all customers against OFAC’s list of Specially Designated Nationals and Blocked Persons (the “SDN List”) and other applicable government lists at onboarding and on an ongoing basis, and we conduct real-time screening of transactions and counterparties. Where required by law, we will reject transactions, block assets, and file reports with the relevant authorities.
9. Reservation of Rights
We may decline, suspend, restrict, or terminate any customer relationship, card, account, or transaction, without prior notice, where we determine in our sole discretion that continued provision of services would present unacceptable legal, regulatory, sanctions, reputational, or financial-crime risk, or would breach this Prohibitions List, our Terms and Conditions, or applicable law. This Prohibitions List is not exhaustive; we apply a risk-based approach and may prohibit or restrict additional customers, jurisdictions, businesses, or activities at any time.
If you have questions about this Prohibitions List, contact us at support@nsave.com.
