Introduction
A restricted business list is a critical component of Dime’s compliance and risk management framework. This document outlines the specific types of businesses, industries, and activities that Dime will not engage with or process transactions. The purpose of this list is to mitigate risks associated with high-risk customers, financial crime, and reputational damage.
Restricted Business Categories
1. High-Risk Industries:
Gambling and online gaming
Adult entertainment
Cryptocurrencies (except for lawfully regulated exchanges)
High-risk online marketplaces
Firearms, ammunition, and other weapons (e.g., SAP gloves, expandable batons, stun guns), that are illegal in the jurisdictions in which we operate.
Counterfeit goods and services
Ponzi schemes and pyramid schemes
Multi-level marketing with unrealistic earning claims
2. Sanctioned Entities and Individuals:
Entities and individuals listed on international sanctions lists (e.g., OFAC, UN, EU)
Entities and individuals subject to domestic sanctions or watchlist
3. Financial Crime:
Money laundering
Terrorist financing
Bribery and corruption
Fraud (including identity theft, credit card fraud, and wire fraud)
Cybercrime (e.g., hacking, phishing, ransomware)
4. Illegal Activities:
Drug trafficking and sale of drugs or controlled substances (including paraphernalia associated with drug use)
Human trafficking
Counterfeit currency
Illegal gambling
Environmental crimes
Intellectual property infringement
5. High-Risk Customers and Businesses:
Politically Exposed Persons (PEPs) without adequate due diligence
Shell companies and anonymous entities
Businesses with a history of regulatory violations or criminal activity
High-risk jurisdictions (countries with weak AML/CFT regimes)
Cash-intensive businesses
Businesses with complex ownership structures
6. Other Restricted Activities:
Transactions involving bearer instruments (e.g., bearer bonds, bearer shares)
Transactions with a high degree of anonymity or secrecy
Transactions with unusual patterns
Transactions involving jurisdictions with known tax haven status
Additional Considerations
• Dime reserves the right to conduct enhanced due diligence on any customer or transaction, regardless of whether they fall within the restricted business categories.
• Dime may restrict a Seller's access to certain payment methods if the nature of their business does not align with the respective payment method's Acceptable Use Policy.
• This list is not exhaustive and may be updated from time to time to reflect changes in the regulatory environment and risk assessment.
• Dime will implement appropriate customer acceptance policies, ongoing monitoring, and reporting procedures to manage the risks associated with restricted business activities.
By maintaining a strict adherence to this restricted business list, Dime demonstrates its commitment to responsible financial practices and safeguarding its reputation.