Legal Documents
[I] Prohibitions
Bilder has no appetite for customers or contractors who engage in any of the following:
- Intentional or willfully negligent breaches of law, regulation or policy concerning Financial Crime;
- Repeated unintentional or repeated accidental breaches of law, regulation or policy concerning Financial Crime;
- Misusing Bilder products and services for the purpose of Financial Crime;
- Facilitating business activities, which could be interpreted as a tax offence; and
- Refusing or avoiding to provide sufficient information or documentation to demonstrate compliance.
Bilder will not knowingly enter into a business relationship with persons that seek to process payments involving:
- Illegal Gambling entities;
- Weapon dealers/intermediaries/purchasers*;
- Illegal drugs or precursors;
- Anonymous accounts or customers seeking to maintain an account in an obviously fictitious name;
- Human trafficking or modern slavery;
- Shell Banks ** or financial institutions which cooperate with Shell Banks;
- Illegal adult content ***
- Rape/hate/violence;
- Replica/Copyright infringement;
- Companies which issue bearer shares; ****
- Unlicensed financial institutions;
- Privacy coins, e.g. Monero, Zcash and Dash;
- Ponzi / pyramid schemes;
- Binary options; and
- ICO incl. subscriptions, placement or distribution
* Weapons of war, automatic weapons, ammunition or defence equipment, chemical weapons, cluster bombs, ammunitions, or other defence equipment or similar;
** Shell Banks are financial institutions with no physical presence, staff and management in the jurisdiction where they are incorporated or licensed.
*** Video (online, streaming, webcam), audio, photo, drawings (arts)) incl., but not limited to offensive sexual content, extreme violence, child exploitation, non-consensual material, bestiality, self-harm content, Any conduct in breach of moral and ethical standards or suicide; live escort or prostitution services and any supporting activities of it.
**** Bearer shares refer to negotiable instruments that accord ownership in a legal person to the person who possesses the physical bearer share certificate, and any other similar instruments without traceability. It does not refer to dematerialised and/or registered forms of share certificates, whose owner can be identified.
Bilder’s risk appetite with respect to higher-risk customers focuses on the ongoing processes of developing, updating and implementing internal controls to detect, prevent and minimise the risk of Bilder being used for Financial Crime. Bilder uses appropriate measures and controls to mitigate the potential Financial Crime risk of customers/transactions. These measures include:
- Increased awareness of higher-risk situations within business lines through enhanced and specialised training;
- Increased levels of know your customer (“KYC”) and know your customer’s business (“KYCB”) and enhanced due diligence for high-risk customers, including PEPs;
- Escalation for approval of the establishment of new, or the maintenance of existing, business relationships;
- Quality assurance of customers’ onboarding by both the AML and Compliance teams;
- Periodic KYC reviews for all customers, which include a review of documents obtained during onboarding to ensure they remain up to date, as well as ongoing scrutiny of the customer’s transactions;
- Customer and payment screening for sanctions purposes;
- Combination of automated and manual online transaction monitoring;
- Automated transaction monitoring of all transactions post-event;
- Control of Financial Crime risk exposure.
Bilder reserves the right to decline to establish, or to terminate, a business relationship with customer whose Financial Сrime or other risks cannot be adequately controlled on the basis of the information available, including where such information is missing or insufficient, as well as in cases where it is not possible to obtain reliable confirmation of the reasonable economic substance and/or legitimate purpose of their business or personal activities.
[II] Sanctions Risk Appetite
(A) Bilder has no appetite for customers who are:
- Persons who are subject to sanctions or embargoes (incl. asset freeze) imposed by His Majesty Treasury (HMT), European Union (EU), United Nations (UN) or US Department of the Treasury’s Office of Foreign Assets Control (OFAC);
- Persons or entities engaged in, attempting to engage in, or facilitating activities that breach, evade, or are intended to circumvent sanctions or embargoes imposed by the UK, EU, UN, or OFAC. This includes the use of intermediaries, complex ownership structures, or other arrangements to disguise the involvement of sanctioned parties;
- Persons or entities that require, but do not hold, valid general or specific licences, permits, or other authorisations from competent authorities to undertake activities falling within the scope of applicable sanctions or embargoes;
- Persons or entities in breach of the terms of such licences, permits, or authorisations;
- Persons or entities engaged in prohibited trade or financial activities with sanctioned jurisdictions, governments, or sectors, including but not limited to arms trade, proliferation financing, or export of restricted goods and technologies;
- Persons or entities providing financial, technical, logistical, or any other form of support to sanctioned persons, entities, or activities, whether directly or indirectly.
- Legal entities established in Russia or Belarus, or legal entities in which natural persons residing in Russia or Belarus, individually or collectively, have more than 25% of shares or voting rights;
- Natural persons residing in Russia or Belarus;
(B) Bilder is committed to full compliance with applicable sanctions laws and regulations. In support of this commitment, the following key controls and measures are in place:
Sanctions Screening: Bilder conducts screening of customers (incl.payer/payee) and transactions against HMT, EU, UN, OFAC sanctions lists.
Prohibition of Non-Compliant Activities: Bilder prohibits any business activity that it considers may breach applicable sanctions laws or internal policies. This includes the initiation or continuation of customer relationships, the provision of products or services, or the facilitation of transactions involving:
- Sanctioned individuals or entities;
- Activities directly or indirectly involving jurisdictions subject to comprehensive sanctions.
Restrictions on Targeted Sanctions Exposure: For jurisdictions or persons subject to targeted or sectoral sanctions, Bilder applies enhanced restrictions. These may limit the availability of specific products or services and constrain the types of transactions that may be processed.
Alert Management and Due Diligence: All alerts and potential matches identified by Bilder’s sanctions screening systems are subject to thorough investigation. While every effort is made to resolve these in a timely manner, transaction processing may be delayed to allow for the completion of appropriate due diligence and the collection of necessary information regarding the transaction and involved parties.
Blocks and Asset Freeze: If a customer, payer or payee, of financial institution is found to be in breach of, or meets the criteria set out in, Subchapter II(A), payment transactions to or from that customer may be blocked or subject to an asset freeze, depending on the circumstances. Such measures may be applied by Bilder, its correspondent banks, or other counterparties, in accordance with applicable regulations, internal policies, or at the instruction of the relevant authorities. Accounts and assets held with Bilder may also be blocked or frozen, either temporarily during an internal investigation or as required under legal or regulatory obligations.
Regulatory Reporting: Any actual or suspected breaches of sanctions laws, including any attempts to circumvent applicable measures, are reported promptly to the relevant regulatory authorities in accordance with legal obligations.
Training and Awareness: All relevant staff receive regular, mandatory training to ensure they remain informed of applicable sanctions regimes, regulatory developments, and Bilder’s internal compliance requirements.
[III] Banned CountriesNb
Bilder has no appetite for customers or contractors who are registered, or are citizens or residents, of the following countriesR. Further, we should not accept payments from these countries, either from the customer directly or via the customer’s business partners:
- Afghanistan
- Burundic
- Cambodiac
- Cameroonc
- Central African Republic
- Chadc
- Cuba
- Eritreac
- Ethiopia
- North Korea (DPRK)
- DR Congoc
- Haitic
- Iran
- Iraq
- Lebanon
- Libya
- Malic
- Mozambiquec
- Myanmar (Burma)c
- Nicaraguac
- Pakistanc
- Palestine
- Senegalc
- Sierra Leone
- Somalia
- South Sudan
- Sudan
- Ugandac
- Venezuela
- Yemen
- Zimbabwe
- Government and non-government controlled Ukrainian territory**
- Contested territories that are not internationally recognised: Transdniestria, The Crimea Region (Ukraine), Abkhazia, South Ossetia etc.***
Nb If a new country is added to the Banned Country list, Bilder may continue business relations with a customer who is a resident or citizen of that country, subject to the relevant decision of the FCC.
R The ban on account opening applies to citizens of the banned countries, irrelevant of their place of residence, and to the legal entities or other undertakings incorporated or registered in the banned countries. If a legal entity is registered in a country that is not banned, the fact that one of its beneficial owners is a citizen of a banned country but legally lives abroad with a valid residence permit does not prevent account opening.
** Means areas of the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts; We do not open accounts for clients from these territories; However, the payments from/to Ukrainian governmentally controlled territories of Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts could be made, if it does not breach the sanctions and relevant UK law (manual control is applied).
*** Contested territories that are not internationally recognised refer to regions that have declared independence or autonomy from a recognised state, but their sovereignty is not recognised by the international community.
Cards services related limitations
Bilder Cards are not operating in Ethiopia, Russia and Banned Countries (except for those Banned Countries marked as “c” ). Operations of the Cards in Belarus are limited.
Approved on 04/11/2025 Board meeting
