Draft, pending legal review.
This document has been prepared for review by Canadian financial services counsel and is not yet in force. Items in square brackets are unconfirmed and must not be relied upon. It will be published with a version and an effective date before the service accepts customers.
1. Purpose and scope
This Acceptable Use Policy forms part of our Terms of Service. It applies to everyone who uses Nomos Pay, including individuals, businesses, and the authorised users, directors and beneficial owners of business accounts.
It applies to every part of the services, including accounts, balances, payments, conversions, digital asset transfers, any card product, and our website and applications.
2. Your core obligations
- Use the services lawfully, and comply with all laws that apply to you.
- Give us accurate, complete and current information, and update it when it changes.
- Use your account only for the activity and purpose you have declared to us.
- Keep your credentials, devices and second factors secure, and do not share them.
- Operate your account for yourself, or for the business you have told us about, and not for an undisclosed third party.
- Cooperate with reasonable requests for information about your activity, your funds and your counterparties.
3. Financial crime
You must not use the services for, or in connection with, any of the following.
- Money laundering, or handling the proceeds of crime.
- Terrorist financing, or the financing of proliferation.
- Sanctions evasion, or any attempt to breach, avoid or circumvent a sanctions measure.
- Transacting with, or for the benefit of, a person, entity, vessel or jurisdiction subject to sanctions.
- Bribery, corruption, or facilitating a tax offence.
- Fraud of any kind, including payment fraud, identity fraud and application fraud.
- Handling stolen funds, stolen assets or assets obtained through ransomware, extortion or theft.
- Concealing the source, ownership or destination of funds, including through layering or structuring transactions to avoid reporting thresholds.
4. Prohibited business activity
We cannot support accounts engaged in the following activities. Some are unlawful everywhere; others are restricted by our partners or by our own risk appetite.
- Unlicensed financial services, including operating as an unregistered money services business, exchange, payment provider or deposit taker.
- Investment scams, Ponzi and pyramid schemes, high-yield investment programmes, and any offering that guarantees returns.
- Fraudulent or misleading fundraising, including deceptive token offerings.
- Market manipulation, wash trading, spoofing, and the generation of artificial volume.
- Mixing, tumbling and other services whose purpose is to obscure the origin of digital assets.
- Darknet marketplaces, and any service facilitating access to them.
- Ransomware, malware, hacking services, credential marketplaces and other cybercrime.
- Trade in illegal goods or services, counterfeit goods, or goods that infringe intellectual property.
- Controlled substances and drug paraphernalia, where prohibited by applicable law.
- Weapons, ammunition, explosives and related components, where prohibited by law or by our partners.
- Gambling and gaming, where unlicensed or prohibited in the relevant jurisdiction.
- Adult services, where unlawful, non-consensual, or prohibited by our partners.
- Human trafficking, exploitation, child sexual abuse material, and any activity causing serious harm to a person.
- Wildlife trafficking, and trade in protected species or cultural property.
- Shell companies with no verifiable business activity, and structures designed to obscure beneficial ownership.
We maintain additional restricted business and restricted jurisdiction lists, which reflect the requirements of our banking, payment and custody partners, applicable law, regulatory expectations and our own risk appetite. These lists change, and an activity not named here may still be unsupported.
5. Misuse of the platform
- Providing false, misleading or forged information or documents during verification or at any other time.
- Opening an account in a false name, or on behalf of an undisclosed person, or operating a nominee account.
- Using another person's identity, credentials or payment instruments.
- Sharing credentials, or allowing a third party to access or operate your account.
- Operating multiple accounts to evade limits, restrictions, fees or a prior closure decision.
- Circumventing or attempting to circumvent our controls, including geographic restrictions, transaction limits, screening or verification.
- Passing third-party funds through your account, or acting as a conduit for someone else's transactions.
- Using the services from a restricted jurisdiction, or concealing your location.
- Abusive, threatening or harassing behaviour towards our staff or other customers.
6. Technical misuse
- Unauthorised access, or attempted access, to any part of our systems or another customer's account.
- Introducing malware, or interfering with the integrity or performance of the platform.
- Denial of service attacks, automated abuse, credential stuffing and unauthorised scraping.
- Reverse engineering, decompiling or attempting to derive source code, except where the law permits it.
- Exploiting a bug, pricing error or system fault rather than reporting it, and retaining any benefit obtained.
- Using the services to build a competing product, or reselling access without our written consent.
If you discover a security vulnerability, report it to [COMPLIANCE EMAIL] or the security contact on our security page. We do not pursue researchers who report issues in good faith and do not access data belonging to other people.
7. How we enforce this policy
Where we believe this policy has been breached, or where we are required to act by law, a regulator or a partner, we may take any of the following steps, with or without prior notice.
- Request further information or documentation from you.
- Delay, refuse, block or reverse a transaction.
- Limit functionality, reduce limits, or restrict access to part of the services.
- Hold or freeze a balance where required or permitted by law.
- Suspend or close your account, and terminate our relationship.
- Retain records, and report the matter to a regulator, a law enforcement agency or a partner.
- Recover amounts owed to us, and pursue legal remedies.
8. Notice, review and appeals
We will tell you when we take action, and explain the reason, unless we are prohibited from doing so by law or doing so would prejudice an investigation. In some circumstances we are legally prevented from telling you anything at all, including that a report has been made.
If you believe a decision was wrong, you can ask us to review it by contacting [COMPLIANCE EMAIL], or by raising a formal complaint under our Complaints Policy. A person who was not responsible for the original decision will review it wherever practicable.
9. Changes to this policy
We may update this policy, including the restricted activity and jurisdiction lists, at any time. Material changes will be notified in accordance with the Terms of Service. Continuing to use the services after a change takes effect means you accept it.
Entity and contact details
These details will be completed and confirmed by counsel before publication. Where a placeholder appears below, the information has not yet been confirmed and must not be relied upon.
| Item | Detail |
|---|---|
| Legal entity | [LEGAL ENTITY NAME] |
| Trading name | Nomos Pay |
| Registered office | [REGISTERED ADDRESS] |
| Incorporation number | [INCORPORATION NUMBER] |
| FINTRAC MSB registration | [FINTRAC MSB REGISTRATION NUMBER] |
| Website | nomos-pay.com |
| General support | [SUPPORT EMAIL] |
| Legal | [LEGAL CONTACT EMAIL] |
| Privacy | [PRIVACY EMAIL] |
| Complaints | [COMPLAINTS EMAIL] |
| Compliance | [COMPLIANCE EMAIL] |
| Telephone | [PHONE NUMBER] |
| Effective date | [DATE] |
| Last updated | [DATE] |
Questions about this document, or need it for a diligence process? Contact [LEGAL CONTACT EMAIL] . To raise a formal complaint, see our complaints policy.