[I] Prohibitions

Bilderlings 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 Bilderlings 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.

Bilderlings is aiming to conduct business only with reputable customers or vendors and whose identities can be reliably determined and verified.

Bilderlings reserves the right to terminate relationships with any customer or vendors, refuse payment, or business that is not compliant with Bilderlings’ risk appetite.

Bilderlings 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, i.e. banks with no physical presence or staff, or financial institutions which cooperates with shell banks;
• Adult-online live content, webcam, online streaming content and acts of offensive adult content, Adult advertising, Child Pornography, Bestiality;
• 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
** 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 certificate whose owner can be identified.

Bilderlings Risk Appetite with respect to higher risk customers focuses on the establishment of ongoing processes of developing, updating and implementing internal controls, in order to detect, prevent and minimise the risk of Bilderlings being used for Financial Crime. Bilderlings uses appropriate measures and controls to mitigate the potential Financial Crime risk of those customers/transactions that are determined as high risk. 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 a new, or the maintenance of an existing, business relationship;
• Quality Assurance of customer’s onboarding by both the AML and Compliance teams;
• Periodic KYC reviews for all customers, which includes a review of all KYC 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 on-line transaction monitoring;
• Automated transaction monitoring of all transactions post event.