Prohibited and Restricted Businesses

Grid is a low-level payment infrastructure API that enables modern financial institutions, businesses, or any developer to send, receive, and settle value globally across fiat currencies, stablecoins, and Bitcoin. Lightspark Payments, LLC (LSP) is a regulated financial services company that has to adhere to financial laws and regulations, as well as rules and policies set by our financial partners.

This page provides information on the types of businesses, products, and industries that can't use LSP's services. To use LSP's services, you must remain compliant with these rules and restrictions.

Prohibited Activities — Activities that are strictly prohibited in connection with LSP's services.

Prohibited Customers — Types of customers that are not permitted to use LSP's services.

Restricted Businesses — Types of businesses that may use LSP's services only with prior approval and subject to enhanced due diligence.

Prohibited Jurisdictions — Countries and territories from which LSP will not onboard customers or facilitate transactions.

In connection with the use of our services or in the course of interactions with LSP, the following are strictly prohibited:

Illegal Use: Using our service for any illegal purposes or in breach of any applicable law, including fraud, the funding of terrorist organizations, and money laundering.

Prohibited Goods and Services: Using the service for the purchase or sale of:

• Sexually-oriented materials or services.
• Gambling activities that are illegal under applicable federal or state law, including activities prohibited by the Unlawful Internet Gambling Enforcement Act (UIGEA), or services provided by unregulated casinos or gaming establishments.
• Tobacco or tobacco-related paraphernalia.
• Firearms or weapons by unlicensed or improperly licensed dealers.
• Prescription drugs or other controlled substances, including Delta-8 THC and Delta-9 THC products, kratom and alkaloid-based products, and precursor chemicals.

Exploitative or Fraudulent Schemes: Engaging in or facilitating pyramid schemes, Ponzi schemes, or other fraudulent or deceptive investment operations.

Human Exploitation: Engaging in or facilitating human trafficking, child exploitation, or other human rights abuses.

False Information: Providing material false, inaccurate, or misleading identifying information during account creation or onboarding in response to requests for information to execute a transaction.

Lack of Cooperation: Refusing to cooperate in any investigation or provide requested information or confirmation regarding your identity or use of our service.

LSP has identified the following types of customers that are prohibited:

• Countries, governments, entities, and individuals subject to economic sanctions, including those identified on the U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List, or any other applicable internal or external blocklist;
• Defense sector or the manufacture or production of arms, military equipment, or weapons of mass destruction;
• Private military contractors;
• Unlicensed or unregistered Money Services Businesses (MSBs) and unregulated financial services;
• Unlicensed or unregistered virtual asset service providers (VASPs);
• Missions, embassies, and consulates;
• Shell banks or shell companies with no physical presence in any regulated jurisdiction;
• New bearer share issuance or issued bearer shares that have not been immobilized or are not with an approved custodian;
• Any customer attempting to use anonymous or numbered accounts, anonymous internet-based payment platforms, or customers seeking to maintain an account in an obviously fictitious name;
• Customers whose identities are not known or cannot be verified;
• Customers exited for financial crime concerns. In addition, customers or related parties where there is a strong suspicion or direct evidence that criminal activity has taken place, where a criminal offence has been committed and charges have been brought or where there is a suspicion of terrorist financing;
• Marijuana Related Businesses (MRBs) and cannabis-related businesses that operate in violation of applicable federal law. Businesses operating under a valid license in U.S. states or jurisdictions where cannabis is legally permitted may be considered under LSP's Restricted Businesses policy;
• Counterfeit goods or services;
• Crypto Mining Industries;
• Operators of Bitcoin or other cryptocurrency ATMs or kiosks;
• Payable Through Accounts;
• Third-party payment processors engaged in unlawful transactions;
• Unlawful Internet Gaming Companies, their principals, their payment processors, and any of their affiliated entities or activities;
• Digital currency services or platforms with material AML/CFT compliance concerns (e.g., Binance and Binance US);
• Rough gems, precious metals;
• Payday lenders, their owners, and principals; and
• Verified hackers.

Certain businesses may use LSP's services only with prior written approval and are subject to enhanced due diligence (EDD) and ongoing monitoring requirements. LSP reserves the right to decline any application or terminate services at its sole discretion. Businesses in the following categories must contact LSP before onboarding:

• Adult entertainment businesses, escort services, and sexually oriented or pornographic products and services;
• Armored courier services;
• Art and antiquities dealers;
• Banking-as-a-service (BaaS) relationships, including third parties that use LSP's services as infrastructure to provide financial services to their own downstream customers;
• Cannabis-related businesses operating under a valid license in U.S. states or jurisdictions where cannabis is legally permitted;
• DeFi protocols and stablecoin issuers;
• Extractive industries and energy companies;
• Firearms and weapons dealers operating under valid applicable federal and state licenses;
• Foreign correspondent banks;
• Foreign investment entities;
• Foreign non-governmental organizations (NGOs);
• Import/export businesses;
• Legal gambling entities and licensed casinos;
• Licensed Money Services Businesses (MSBs);
• Luxury goods dealers, including dealers in luxury vehicles, yachts, aircraft, and artwork;
• Military contractors (other than private military contractors, which are prohibited);
• Non-bank financial institutions;
• Non-U.S. entities;
• Pawn shops and pawn brokers;
• Pharmaceuticals and healthcare businesses;
• Political organizations, including political action committees (PACs) and similar entities;
• Private ATM owner/operators;
• Professional service providers acting as financial gatekeepers, including attorneys, accountants, notaries, and trust and company service providers;
• Real estate agents and developers;
• Travel and tour agencies; and
• Used car dealerships.

LSP will not onboard customers or facilitate transactions involving residents, entities, or transactions initiated to or from the following jurisdictions. Case-by-case exceptions may be permitted where authorized under applicable law, including OFAC Special Licenses or General Licenses.

Prohibited Countries:

Afghanistan, Belarus, Bhutan, Burundi, Congo (Democratic Republic of the), Cuba, Gaza Strip, Guinea-Bissau, Haiti, Iran (Islamic Republic of), Iraq, Kenya, Kosovo, Lebanon, Libya, Mozambique, Myanmar (Burma), North Korea (Democratic People's Republic of Korea), Pakistan, Qatar, Russian Federation, Somalia, South Sudan, Sudan, Syria, Ukrainian Territories (Crimea, Sevastopol, Donetsk, Kherson, Luhansk, and Zaporizhzhia), Venezuela, West Bank (Palestinian Territory, Occupied), Yemen, and Zimbabwe.

Digital Asset Transactions — Additional Prohibited Countries:

The following countries are additionally prohibited for digital asset transactions and digital asset-related entities: Algeria, Bangladesh, China, Morocco, and Nepal.

This list is reviewed and updated periodically to reflect changes in applicable sanctions, FATF designations, and LSP's banking partner requirements. The most current version of this list governs at all times.