This page sets out categories of business and conduct that are not permitted on the Clearfin clearing service. It applies to every operator on the books, every applicant, every integrator, and every user of the application programming interfaces, dashboards, and websites the house operates. We adopt this page to comply with the operating rules of Visa, Mastercard, American Express, and Discover, with applicable federal and state law in the United States, and with the requirements of our acquiring and processing partners.
We may update this page from time to time. Continued use of the services after a change is acceptance of the change. We may suspend access, hold funds, or end the operating relationship for any breach, with or without notice, consistent with the Operating agreement.
§ 1. Categories of business we do not take
1.1 Adult and sexual content
- Pornography, escort services, and other adult-oriented goods or services.
- Sexually oriented online dating where charges are tied to messaging or matches.
1.2 Gambling and games of chance
- Real-money gambling, sports betting, online casinos, fantasy contests with prizes, lotteries, and sweepstakes operated without proper licensing.
1.3 Controlled substances and prohibited goods
- Illegal drugs, drug paraphernalia, and synthetic cannabinoids.
- Cannabis (THC) products, regardless of state legalisation, except where permitted through licensed and supported processing rails (not currently supported on this clearing service).
- Tobacco, electronic cigarettes, vaping products, and nicotine pouches.
- Firearms, ammunition, and weapons of any kind.
- Prescription pharmaceuticals or controlled substances sold without proper licensing, medical evaluation, or compliance with state and federal law.
1.4 Financial and investment activity
- Multi-level marketing, pyramid schemes, matrix programs, and any recruitment-incentivised commerce model.
- Get-rich-quick schemes, “guaranteed return” offers, and unregistered investment opportunities.
- Unregistered securities, initial coin offerings, and token sales.
- Debt collection, debt-elimination, and credit-repair services.
- Cryptocurrency exchanges, mixers, and unhosted-wallet sales.
- Cash-equivalent businesses including check cashing, money transmission, currency exchange, prepaid-card sales, and unauthorised money services.
1.5 Deceptive marketing and consumer harm
- Negative-option subscriptions or hidden recurring charges that fail to disclose the terms before purchase.
- Deceptive advertising, including bait-and-switch, false-scarcity, manipulated testimonials, or unsubstantiated health, weight-loss, or income claims.
- Telemarketing or outbound calling that does not comply with the Telephone Consumer Protection Act, Do-Not-Call regulations, or state telemarketing law.
- Unsolicited bulk commercial email that violates CAN-SPAM or equivalent law.
1.6 Intellectual-property infringement and counterfeit goods
- Sale of counterfeit, replica, or unauthorised branded merchandise.
- Unlicensed sale of copyrighted material, including pirated software, media, e-books, and streaming content.
1.7 Hate, violence, and extremism
- Goods or services promoting hate, violence, or discrimination on the basis of race, ethnicity, religion, gender, sexual orientation, disability, or national origin.
- Sale of materials supporting designated terrorist or extremist organisations.
1.8 Network and acquirer restrictions
- Any business listed on Visa BRAM (Brand Risk and Anti-Money-Laundering), Mastercard BAU (Business Risk Assessment and Mitigation), or an equivalent restricted-business program.
- Any business in a category for which our acquiring or processing partners have not provided processing support.
- Aggregation, factoring, or processing payments on behalf of an unrelated party.
1.9 Other prohibited activity
- Illegal activity of any kind under U.S. federal or applicable state law.
- Violations of U.S. export control or sanctions law, including transactions involving jurisdictions or persons subject to OFAC sanctions.
- Activities likely to attract excessive disputes or that we identify as high-risk fraud.
- Use of the platform to transmit malware, run denial-of-service attacks, or otherwise harm the security or integrity of our infrastructure or third-party systems.
§ 2. Reporting a violation
If you believe an operator on the books is in breach of this page, please write to info@clearfin.dev. Reports are read by the compliance staff and, where warranted, escalated for action.
§ 3. Enforcement
We investigate suspected breaches and take action consistent with our risk and compliance program, the operating rules of the card networks, and applicable law. Action may include warnings, increased monitoring, reserves, payout holds, account suspension, or termination, and may be reported to acquirers, networks, or authorities where appropriate.