Acceptable Use Policy

2. Scope

This Policy applies to:

1. all Goat Finance customers;

2. all applicants;

3. all users of Goat Finance websites, platforms, portals, communication channels or services;

4. individuals;

5. legal entities;

6. beneficial owners;

7. directors, officers, representatives and signatories;

8. counterparties involved in transactions;

9. any person or entity using, attempting to use, or benefiting from Goat Finance services.

This Policy applies across the Goat Finance multilateral organization, including each Goat Finance entity that provides, supports, operates, controls, processes, or facilitates a Goat Finance service.

This Policy also applies where a Goat Finance service is supported by a banking, payment, liquidity, settlement, infrastructure, compliance, blockchain analytics, KYC/KYB, technology or other partner.

3. Relationship With Other Documents

This Policy must be read together with:

1. the Goat Finance Global Terms and Conditions;

2. the applicable entity-specific Terms of Use;

3. any product-specific Terms of Use, disclosure or agreement;

4. the Goat Finance Digital Asset Risk Disclosure;

5. the Goat Finance Global Privacy Policy;

6. the applicable Phase 1 or entity Privacy Notice;

7. any partner-specific disclosure, acknowledgment or restriction presented to you.

If a product-specific disclosure or partner-supported service imposes additional restrictions, those additional restrictions apply together with this Policy.

If there is a conflict between this Policy and a stricter requirement imposed by law, regulation, sanctions controls, a banking partner, a payment partner, a liquidity provider, a settlement provider, a crypto provider, a regulator or a product-specific disclosure, the stricter requirement will apply.

4. No General Availability or Solicitation

Publication of this Policy on the Goat Finance website does not mean that any Goat Finance product or service is available in your jurisdiction.

Nothing in this Policy constitutes:

1. an offer of services;

2. a solicitation;

3. a financial promotion;

4. an invitation to transact;

5. investment advice;

6. legal or tax advice;

7. a representation that you are eligible to use any Goat Finance service.

All services are subject to onboarding, eligibility assessment, compliance approval, risk review, applicable law, product availability and, where relevant, partner approval.

5. General Risk Appetite

Goat Finance may accept, reject, restrict, suspend, terminate or subject a customer, transaction, asset, jurisdiction, occupation, business, wallet, payment method or activity to enhanced due diligence based on Goat Finance’s risk appetite.

Goat Finance may consider, among other things:

1. jurisdictional risk;

2. sanctions exposure;

3. AML/CFT risk;

4. proliferation financing risk;

5. fraud risk;

6. corruption or bribery risk;

7. source of funds;

8. source of wealth;

9. transaction purpose;

10. customer profile;

11. industry risk;

12. occupation risk;

13. ownership structure;

14. politically exposed person status;

15. adverse media;

16. wallet risk;

17. blockchain analytics results;

18. transaction behavior;

19. product requested;

20. partner requirements;

21. banking or payment restrictions;

22. regulatory perimeter risk;

23. operational risk;

24. reputational risk.

Goat Finance may apply stricter standards than those required by law, external public lists or third-party frameworks.

6. Approved Assets Only

You may only use assets, networks, wallets, payment methods and settlement methods approved by Goat Finance for your specific route.

Approval may depend on:

1. the contracting entity;

2. the customer type;

3. the jurisdiction;

4. the service requested;

5. the partner framework;

6. asset classification;

7. liquidity availability;

8. settlement feasibility;

9. blockchain analytics results;

10. legal and regulatory analysis;

11. sanctions and financial crime controls;

12. internal risk appetite.

Goat Finance may discontinue, suspend, limit or delist any asset, network or settlement method at any time.

7. Prohibited Persons and Parties

7.1 Prohibited Jurisdictions

Goat Finance does not accept customers, applicants, beneficial owners, controllers, counterparties, transactions, source of funds, source of wealth, wallets, payment flows, business activity or operations connected to any jurisdiction identified by the Financial Action Task Force as a High-Risk Jurisdiction subject to a Call for Action, commonly referred to as the FATF “blacklist”.

FATF public materials on high-risk and monitored jurisdictions are available at:
https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html

This restriction applies where the relevant FATF-listed jurisdiction is connected to, among other things:

1. the customer’s residence, incorporation, registration or place of business;

2. the customer’s beneficial ownership or control structure;

3. the customer’s directors, officers, authorized representatives or signatories;

4. the customer’s source of funds or source of wealth;

5. the customer’s bank account, wallet, payment method or settlement route;

6. the customer’s transaction counterparty;

7. the origin, destination or purpose of a transaction;

8. any other material connection identified during onboarding, screening, transaction monitoring or ongoing due diligence.

Goat Finance may reject, suspend, terminate, block, return, freeze or report any relationship or transaction involving a FATF High-Risk Jurisdiction subject to a Call for Action.

Goat Finance may rely on FATF public statements and materials identifying high-risk jurisdictions subject to a call for action. FATF publishes public documents identifying jurisdictions with weak AML/CFT measures, including high-risk jurisdictions subject to a call for action and jurisdictions under increased monitoring. (fatf-gafi.org)

Goat Finance may also apply stricter internal restrictions than those reflected in FATF public materials.

7.2 Sanctions-Listed Persons and Restricted Parties

Goat Finance does not accept any customer, applicant, beneficial owner, controller, director, officer, authorized representative, signatory, counterparty, wallet, payment flow or transaction that is listed on, owned or controlled by, acting for or on behalf of, or otherwise materially connected to any applicable sanctions list.

This includes, without limitation:

1. the U.S. Office of Foreign Assets Control Specially Designated Nationals and Blocked Persons List;

2. the U.S. OFAC Consolidated Sanctions List;

3. United Nations sanctions lists;

4. European Union sanctions lists;

5. United Kingdom sanctions lists;

6. Swiss sanctions lists;

7. Canadian sanctions lists;

8. any other sanctions, asset-freezing, terrorist financing, proliferation financing, export-control or restricted-party list applicable to Goat Finance, its partners, banking providers, payment providers, liquidity providers, settlement providers or the relevant transaction.

Goat Finance may reject, suspend, terminate, freeze, block, return, delay, investigate or report any customer, relationship or transaction where sanctions screening identifies a confirmed match, potential match, ownership or control concern, sanctions nexus or other restricted-party risk.

7.3 Ownership, Control and Acting-on-Behalf Restrictions

Goat Finance does not accept customers or transactions where a person or entity is directly or indirectly owned or controlled by, acting on behalf of, acting at the direction of, or materially benefiting any sanctioned person, blocked person, restricted party or prohibited jurisdiction.

This restriction applies even if the customer, applicant or transaction counterparty does not appear by name on a sanctions list.

Goat Finance may assess ownership, control, influence, benefit, agency, nominee relationships, indirect exposure and circumvention risk using information collected during onboarding, screening, transaction monitoring, blockchain analytics, public records, third-party databases, partner information and other available sources.

Goat Finance may reject, suspend, terminate, freeze, block, return, delay, investigate or report any relationship or transaction where it cannot satisfactorily rule out sanctions ownership, control, benefit, direction, agency, nominee or circumvention risk.

7.4 Sanctions Evasion and Circumvention

You must not use Goat Finance services to avoid, evade, circumvent or attempt to circumvent sanctions, asset freezes, embargoes, export controls, counter-terrorist financing restrictions, proliferation financing restrictions or other financial restrictions.

Prohibited conduct includes, without limitation:

1. using intermediaries, nominees, shell companies, front companies or layered structures to conceal a sanctioned or restricted party;

2. routing payments, cryptoassets or transactions through third countries to avoid sanctions controls;

3. using wallets, mixers, bridges, exchanges or counterparties to obscure sanctions exposure;

4. structuring transactions to avoid screening, limits, monitoring or reporting;

5. misrepresenting residence, incorporation, ownership, control, source of funds, source of wealth, transaction purpose or counterparty information;

6. attempting to transact with, for the benefit of, or on behalf of a sanctioned person, restricted party or prohibited jurisdiction.

Goat Finance may reject, block, freeze, return, suspend, terminate or report any activity that may involve sanctions evasion or circumvention.

7.5 Prohibited Customers and User Types

Goat Finance may prohibit or reject customers, applicants, users or beneficial owners who:

1. provide false, incomplete, misleading, forged or inconsistent information;

2. refuse to provide required information or documentation;

3. attempt to conceal identity, ownership, control, location, residence, source of funds or source of wealth;

4. act as a nominee, strawman, front, shell, mule or undisclosed intermediary;

5. act on behalf of another person without disclosure and approval;

6. are minors;

7. are legally incapable of contracting;

8. are subject to sanctions or other legal restrictions;

9. are associated with fraud, scams, cybercrime, terrorism, organized crime or other unlawful activity;

10. use anonymity-enhancing methods to evade onboarding, screening, transaction monitoring or jurisdictional controls;

11. use VPNs, proxies, remote access tools or similar methods to misrepresent their jurisdiction or identity;

12. operate a structure that cannot be understood or verified to Goat Finance’s satisfaction;

13. fall outside Goat Finance’s risk appetite.

7.6 Prohibited Industries and Activities

You must not use Goat Finance services for any illegal, prohibited or unsupported activity.

Prohibited activities include, without limitation:

1. money laundering;

2. terrorist financing;

3. proliferation financing;

4. sanctions evasion;

5. fraud;

6. scams;

7. tax evasion;

8. bribery or corruption;

9. human trafficking;

10. child exploitation;

11. illegal drugs or controlled substances;

12. illegal gambling;

13. illegal weapons or prohibited military goods;

14. counterfeit goods;

15. stolen goods;

16. ransomware;

17. cybercrime;

18. darknet market activity;

19. market manipulation;

20. insider dealing;

21. unauthorized financial services;

22. unlicensed money transmission;

23. unlicensed payment processing;

24. unlicensed investment services;

25. undisclosed merchant acquiring or merchant collection;

26. pyramid schemes;

27. Ponzi schemes;

28. investment scams;

29. romance scams;

30. mule activity;

31. unauthorized third-party money movement;

32. any activity that violates applicable law, regulation, sanctions rules, partner requirements or Goat Finance’s risk appetite.

Goat Finance may reject, suspend, block, return, freeze, terminate or report any activity it reasonably believes may involve prohibited activity.

7.7 Prohibited Transaction Behavior

You must not use Goat Finance services to:

1. move funds for another person without disclosure and approval;

2. process third-party payments unless expressly approved;

3. collect, pool or aggregate funds from third parties;

4. send funds to unrelated third parties unless expressly approved;

5. operate as an undisclosed payment intermediary;

6. operate nested financial services;

7. operate an undisclosed broker, agent, payment processor, MSB, VASP, CASP or intermediary model;

8. structure or split transactions to avoid limits, reporting, review or due diligence;

9. disguise the source or destination of funds;

10. disguise beneficial ownership or control;

11. use multiple accounts to avoid monitoring;

12. use false references, false invoices or false transaction purposes;

13. use unsupported wallets, unsupported networks or unsupported assets;

14. route funds through mixers, tumblers, darknet markets or high-risk wallets;

15. use Goat Finance for transactions inconsistent with your approved profile;

16. use Goat Finance for business activities not disclosed or approved during onboarding;

17. use Goat Finance in a manner that would require Goat Finance to hold a license, registration, permission or authorization it does not hold.

7.8 Cryptoasset and Digital Asset Restrictions

Goat Finance supports only digital assets expressly approved by Goat Finance for the relevant service, jurisdiction, customer type and customer profile.

You must not use Goat Finance services for unsupported or restricted assets.

This includes, without limitation, any token or asset that Goat Finance determines may be or may involve:

1. a security;

2. an equity token;

3. a share or stock token;

4. a bond token;

5. a derivative;

6. a structured product;

7. a collective investment scheme;

8. a fund interest;

9. a financial instrument;

10. an e-money token;

11. an asset-referenced token;

12. a stablecoin that is not approved by Goat Finance for the relevant route;

13. a yield-bearing product;

14. a staking, lending or investment product;

15. a tokenized real-world asset;

16. a privacy-enhancing asset;

17. an asset subject to sanctions, freeze, seizure, court order or law enforcement notice;

18. any asset requiring a license, registration, permission or authorization not held by the applicable Goat Finance entity.

Goat Finance may reject, block, return, suspend or terminate any transaction involving unsupported or restricted assets.

FATF’s virtual asset guidance emphasizes a risk-based approach to virtual assets and VASPs. Goat Finance may therefore update its supported asset list and asset-risk controls from time to time based on applicable law, regulatory guidance, FATF materials, partner requirements and internal risk appetite. (fatf-gafi.org)

7.9 Platform, Website and System Misuse

You must not misuse Goat Finance websites, platforms, portals, APIs, systems, forms, onboarding flows, communication channels or services.

Prohibited conduct includes:

1. unauthorized access;

2. credential sharing where prohibited;

3. account takeover;

4. phishing;

5. impersonation;

6. social engineering;

7. malware;

8. denial-of-service attacks;

9. scraping;

10. automated extraction;

11. reverse engineering;

12. decompiling;

13. tampering;

14. bypassing security controls;

15. bypassing onboarding controls;

16. creating duplicate or false accounts;

17. submitting forged documents;

18. submitting manipulated images or deepfakes;

19. interfering with service availability;

20. attempting to discover or exploit vulnerabilities;

21. using the service in a way that damages Goat Finance, customers, partners or systems.

Goat Finance may monitor system activity for security, fraud prevention, compliance and operational purposes.

8. High-Risk Profiles

Goat Finance may decline any customer or transaction where the risk cannot be understood, mitigated or approved.

8.1 Politically Exposed Persons and Complex Structures

Goat Finance may apply enhanced due diligence, additional approvals, monitoring, restrictions or rejection to:

1. politically exposed persons;

2. family members or close associates of politically exposed persons;

3. customers with complex ownership or control structures;

4. customers using trusts, foundations, nominees or layered entities;

5. customers with opaque source of funds or source of wealth;

6. customers with high-risk jurisdictional exposure;

7. customers with significant cash exposure;

8. customers with high-volume or unusual transaction patterns;

9. customers with adverse media;

10. customers whose profile, business activity or transaction purpose is inconsistent, unclear or unsupported.

8.2 Restricted or Enhanced-Risk Jurisdictions

Some jurisdictions may not be automatically prohibited but may require enhanced due diligence, additional documentation, senior approval, partner approval, transaction limitations, reduced limits, manual review or ongoing monitoring.

This may include jurisdictions:

1. identified by FATF as under increased monitoring;

2. identified by Goat Finance as higher risk;

3. associated with elevated corruption risk;

4. associated with elevated organized crime risk;

5. associated with elevated fraud or cybercrime risk;

6. associated with weak AML/CFT controls;

7. associated with limited transparency or weak beneficial ownership information;

8. subject to heightened regulatory, banking, partner or payment restrictions;

9. where the customer, counterparty, source of funds or transaction purpose requires additional review.

FATF materials distinguish high-risk jurisdictions subject to a call for action from jurisdictions under increased monitoring. Jurisdictions under increased monitoring are actively working with FATF to address strategic AML/CFT/CPF deficiencies within agreed timeframes. (fatf-gafi.org)

8.3 Restricted or Enhanced-Risk Industries and Occupations

Goat Finance may apply enhanced due diligence, restrictions, limits or rejection to customers operating in industries, occupations or activities associated with higher AML/CFT, fraud, sanctions, corruption, tax, regulatory, financial crime, consumer harm or reputational risk.

This may include, without limitation:

1. Designated Non-Financial Businesses and Professions;

2. casinos and gambling-related businesses;

3. real estate activities;

4. dealers in precious metals or precious stones;

5. lawyers, notaries, accountants or other independent legal professionals handling client funds or structures;

6. trust and company service providers;

7. cash-intensive businesses;

8. high-value goods dealers;

9. money services businesses;

10. payment processors;

11. cryptoasset businesses;

12. investment or trading businesses;

13. charities, NGOs or nonprofit organizations with high-risk geographic exposure;

14. import/export or trade finance businesses;

15. arms, defense or dual-use goods businesses;

16. adult entertainment;

17. gaming, betting or prize-based businesses;

18. travel, ticketing or voucher businesses with high fraud exposure;

19. businesses with frequent third-party payments;

20. businesses involving complex, high-volume or cross-border flows.

Goat Finance may use FATF publications, including the FATF Glossary, FATF Recommendations, DNFBP-related explanatory materials and other FATF guidance, to assess and update its treatment of higher-risk industries and occupations.

Not all restricted or enhanced-risk industries are automatically prohibited. Goat Finance may approve, restrict, monitor or reject them based on due diligence, risk assessment, product, jurisdiction and partner requirements.

9. Wallet and Blockchain Analytics Restrictions

Goat Finance may use blockchain analytics, wallet screening and transaction monitoring tools.

Goat Finance may reject, delay, block, return, investigate, suspend or terminate transactions or relationships involving wallets, addresses, clusters, counterparties or transaction histories associated with:

1. sanctioned addresses;

2. darknet markets;

3. mixers or tumblers;

4. ransomware;

5. scams;

6. fraud;

7. theft;

8. hacks;

9. malware;

10. terrorist financing;

11. child exploitation;

12. high-risk exchanges;

13. unlicensed or non-compliant VASPs/CASPs;

14. stolen funds;

15. bridge-hopping or layering activity used to obscure origin;

16. chain-hopping intended to avoid detection;

17. high-risk decentralized applications;

18. unexplained source or destination of funds;

19. activity inconsistent with your approved profile.

Goat Finance may request wallet ownership evidence, transaction evidence, source of funds documentation or counterparty information before processing a transaction.

10. Partner-Derived Restrictions

Some Goat Finance services may be supported by banking, payment, liquidity, settlement, infrastructure, technology, compliance, KYC/KYB or other partners.

Where a service is partner-supported, additional partner-derived restrictions may apply.

Goat Finance may incorporate those restrictions into:

1. this Policy;

2. onboarding questions;

3. transaction controls;

4. service eligibility rules;

5. product-specific Terms of Use;

6. disclosures;

7. partner acknowledgments;

8. signed agreements;

9. ongoing monitoring rules.

You must comply with all partner-derived restrictions presented to you or applicable to the service.

Goat Finance may reject, suspend, return, block or terminate a service or transaction where required by a partner, banking provider, payment provider, settlement provider, liquidity provider, regulator, law enforcement authority, court, sanctions authority or other competent authority.

11. Product-Specific Restrictions

Additional restrictions may apply depending on the product, contracting entity, partner framework or approved route.

Examples may include:

1. own-name account requirements;

2. no third-party payments;

3. vIBAN settlement limitations;

4. banking partner restrictions;

5. payment partner restrictions;

6. supported currency restrictions;

7. supported asset restrictions;

8. jurisdictional limitations;

9. end-user restrictions;

10. corporate account restrictions;

11. infrastructure or sub-client restrictions;

12. API usage restrictions;

13. data-sharing and compliance cooperation requirements.

Product-specific restrictions will be described in the applicable Terms of Use, disclosure, onboarding notice, partner acknowledgment or signed agreement.

Approval for one product does not imply approval for another product.

12. Updates to This Policy

Goat Finance may update this Policy from time to time.

Changes may be made to reflect:

1. changes in law;

2. regulatory requirements;

3. sanctions updates;

4. FATF updates;

5. partner requirements;

6. banking or payment restrictions;

7. supported asset changes;

8. risk appetite changes;

9. product changes;

10. financial crime typologies;

11. operational or security requirements.

Changes may take effect immediately where required by law, regulation, regulator, sanctions authority, banking partner, payment partner, liquidity provider, settlement provider, crypto provider, security requirement, financial crime control or risk appetite decision.

The updated version will be published on https://goatfinance.io or made available through the relevant onboarding or service channel.

13. Contact

For questions about this Policy, contact:

Goat Finance Compliance
Email: [email protected]

Entity-specific contact details may be provided in the applicable Terms of Use, privacy notice, product disclosure or onboarding communication.