1. Purpose and Scope
This policy defines the categories of business activity, financial products, and service models that Trillion Digital does not support across any of its institutional trading infrastructure, APIs, systems, or related services.
It forms part of our broader compliance and risk-control framework, which includes robust KYC/KYB onboarding, AML/CFT screening, sanctions checks, and risk-based transaction monitoring.
These are Trillion Digital’s service restrictions, including business categories we choose not to support even where an activity may be lawful. Applicable legal obligations depend on the contracting entity, asset, transaction, and jurisdiction. This policy does not assert that both entities are subject to every financial-services regime or hold permissions under MiCA, EMIR, or a VASP framework.
Both Trillion Capital Markets Inc. and Trillion Capital Markets AG apply these service restrictions alongside their separate legal duties. Mandatory law and the signed agreement govern any enforcement action.
These prohibitions apply globally to all users, beneficial owners, directors, authorized signatories, and trading counterparties interacting with Trillion Digital.
2. Prohibited Business Categories
3. Consequences of Violation
- Restriction or suspension — Activity may be restricted while concerns are assessed, subject to the agreement and applicable law.
- Compliance review — We may request information and review relevant transaction, identity, and security records.
- Termination — A relationship may be ended where contractually and legally permitted. Mandatory reporting or asset restrictions can limit when termination is allowed.
- Asset restrictions — Blocking, freezing, return, or transfer of assets must follow the applicable legal requirements; this policy does not create a general right to seize funds.
- Reporting — Reports are made to competent authorities where required, with applicable confidentiality and non-disclosure safeguards.
- Necessary disclosures — Information is shared with another intermediary or partner only where legally required or permitted, subject to privacy, confidentiality, and restrictions on tipping off.
4. How to Report Suspected Violations
If you observe or suspect prohibited activity on the Trillion Digital platform, report it immediately via:
All reports are confidential and prioritized by our Risk and Compliance divisions.
By accessing any of Trillion Digital’s services, infrastructure, or trading systems, you affirm your continued compliance with this Prohibited Activities Policy. We reserve the right to update this policy at any time in accordance with applicable law or supervisory guidance.
