Acceptable Use Policy (AUP)

1. Overview and Purpose

This Acceptable Use Policy (“AUP”) outlines the prohibited activities and standards of conduct required for all Merchants using the FinTEM orchestration platform. By integrating with our API, you agree to comply with this policy in its entirety. Our goal is to ensure a secure, compliant, and stable financial ecosystem for all regional and international partners.

2. Verification and Licensing Requirements

To maintain access to FinTEM infrastructure, all Merchants must:

2.1. Valid Licensing: Possess and maintain active licenses for their specific business activities (e.g., Forex, iGaming, E-commerce, Gaming) in all jurisdictions where they operate.
2.2. Transparency: Provide accurate and up-to-date corporate information, including Ultimate Beneficial Ownership (UBO) details, during the onboarding process and upon request.
2.3. Onboarding Pre-Approval: FinTEM only provides technical connectivity to Merchants who have successfully cleared the KYC/KYB processes of our upstream Financial Partners (PSPs/Banks).

3. Prohibited Business Activities

The use of FinTEM infrastructure is strictly prohibited for businesses involved in:

3.1. Illegal Products/Services: Sale of illegal drugs, unauthorized prescription medicines, or counterfeit goods.
3.2. Unregulated Financial Services: Unlicensed money transmission, unauthorized currency exchange, or “get-rich-quick” schemes (Ponzi/Pyramid schemes).
3.3. Sanctioned Entities: Any activity involving individuals, entities, or countries listed on international sanction lists (e.g., OFAC, UN, EU, UK Sanctions).
3.4. Fraudulent Conduct: Any activity designed to deceive users, such as phishing, social engineering, or unauthorized card testing.

4. Prohibited Technical Conduct

Merchants are prohibited from engaging in the following technical activities:

4.1. System Abuse: Attempting to bypass the intended orchestration logic or “Smart Routing” parameters to hide transaction origins.
4.2. Security Breaches: Unauthorized probing, scanning, or testing the vulnerability of FinTEM APIs or infrastructure.
4.3. Data Manipulation: Submitting fraudulent metadata or falsified IP addresses to circumvent regional routing rules.
4.4. Reselling Infrastructure: Sub-licensing or reselling access to the FinTEM API to unauthorized third-party merchants (Aggregator-level abuse).

5. Regional Compliance and Restrictions

Due to the high-risk nature of certain regions (e.g., CIS, Africa, Middle East), Merchants must:

5.1. Regional Accuracy: Ensure that transactions routed through regional gateways (like Iraq or Nigeria) comply with local central bank regulations.
5.2. Prohibited Jurisdictions: FinTEM may, at its sole discretion, restrict technical connectivity to certain high-risk jurisdictions to protect the integrity of its global financial network.

6. Monitoring and Enforcement

6.1. Transaction Auditing: While FinTEM does not hold funds, we utilize automated tools to monitor transactional metadata for patterns of abuse, fraud, or system manipulation.
6.2. Right to Suspend: FinTEM reserves the right to suspend or terminate technical access immediately, without prior notice, if a Merchant is found in violation of this AUP or if requested by a law enforcement agency or upstream Financial Partner.
6.3. Reporting Violations: We cooperate fully with global regulatory bodies and will report any suspected illegal activity to the competent authorities (e.g., MASAK, FinCEN).

7. Policy Updates

FinTEM may update this AUP from time to time to reflect changes in global regulations. Continued use of our API after an update constitutes acceptance of the revised policy.