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Prohibited Activities Policy

Last Updated: 4 July 2025

Prohibited Activities Policy

Last Updated: 4 July 2025

1. Purpose & 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 monitoring, and real-time market surveillance.

This policy is designed to ensure Trillion Digital, its clients, liquidity partners, and institutional participants remain fully compliant with:

  • U.S. and international AML/CFT regulations (e.g., BSA, FinCEN, FATF)
  • OFAC, EU, U.K., U.N., and other global sanctions regimes
  • MiCA, EMIR, VASP registration frameworks, and similar asset-specific directives
  • Securities, commodities, derivatives, and consumer protection laws applicable in supported jurisdictions

These prohibitions apply globally to all users, beneficial owners, directors, authorized signatories, and trading counterparties interacting with Trillion Digital.

2. Prohibited Business Categories

#
Category
Description (Non-Exhaustive)
1
Adult Content & Sexually-Oriented Services
Pornographic content, sexually explicit tokens/NFTs, or platforms facilitating commercial sex acts.
2
Drugs, Controlled Substances & Pseudo-Pharmaceuticals
Trade, tokenization, or brokerage of narcotics, unlicensed pharmaceuticals, or “legal high” substances.
3
Weapons, Ammunition & Explosives
Financing or distribution of firearms, explosives, military-grade components, or dual-use technologies.
4
All Gambling & Games of Chance
Any betting platforms, casinos, lotteries, fantasy sports, or chance-based mechanisms, whether licensed or unlicensed, in any jurisdiction.
5
Financial-Crime Schemes & Fraudulent Models
Ponzi structures, HYIPs, spoofing, wash trading, ransomware proceeds, or coordinated market abuse.
6
Hate, Violence, Terrorism & Extremism
Funding or promotion of sanctioned extremist organizations or ideologies.
7
Illegal or Harmful Activities
Human trafficking, child exploitation, wildlife trafficking, or any business criminalized under applicable law.
8
Sanctions & Regulatory Violations
Interactions with sanctioned persons, wallets, or countries in breach of trade or financial controls.
9
Identity Fraud, Anonymity Misuse & Shell Structures
Obfuscation of beneficial ownership, nominee shell companies, or services undermining KYC/KYB clarity.
10
High-Risk Lending & Interest-Based Products
Payday loans, predatory APR products, or unlicensed lending/borrowing schemes (on-chain or off-chain).
11
Governmental, Diplomatic & Political Entities (Restricted)
Engagements with sovereign funds or PEP-linked entities without explicit approval and EDD.
12
Data Misuse & Consumer Privacy Violations
Platforms trafficking in stolen credentials, mass surveillance tools, or violating GDPR/CCPA standards.
13
IP Infringement & Counterfeit Goods
Tokenized or physical assets that infringe copyright, trademark, or trade-secret protections.
14
Obfuscated or High-Risk Privacy Assets
Mixing services, anonymity-enhancing tokens, or assets lacking auditability unless explicitly approved.
15
Unregistered Securities & Derivatives
Offerings of tokenized securities, swaps, or perpetuals without required registration or exemption.

3. Consequences of Violation

  • Immediate Account Suspension – All trading, deposit, and withdrawal functionality may be halted.
  • Comprehensive Review – Including on-chain forensics, wallet-linkage analysis, and IP traceability.
  • Account Termination – Breaching accounts may be off-boarded in accordance with Trillion Digital’s contractual rights.
  • Asset Sequestration – Funds may be retained or transferred to competent authorities if required by law.
  • Regulatory Notification – Suspicious activity may be reported to regulators (e.g., SARs, STRs) without user notice.
  • Counterparty Disclosure – Custodians, liquidity venues, and other partners may be alerted to mitigate broader risk exposure.

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.