Financial Crime Risk Appetite Statement

1. General Restrictions

Restricted Jurisdictions

At this time, we are unable to offer our services and payment instruments to persons and entities residing and (or) or operating in the following countries and jurisdictions:

Restricted Industries and Activities

At this time, we are unable to offer our services and payment instruments to persons and entities associated with the following industries, activities, categories, or risk profiles:

  • Adult entertainment (except dating services);
  • Any illegal activities (including, but not limited to organized crime, drugs, weapons, money laundering, production and distribution of pornographic materials online etc.);
  • Banks (except specialized banks based in EU);
  • Binary options trading & financial products in jurisdictions that do not have or require regulation/licensing;
  • Carbon trading;
  • Cash for gold;
  • Cheque cashing;
  • Counterfeit goods;
  • Development aid;
  • Diamond merchants;
  • Drugs, other psychotropic substances, drug paraphernalia and related;
  • Foreign Politically Exposed Persons, residing outside the EU/EEA;
  • Illegal goods;
  • Medical marijuana/cannabis (if over 0,2% THC);
  • MLM/pyramid schemes;
  • Pawnbrokers;
  • Political parties;
  • Sanctioned persons or entities, their beneficial owners, shareholders, representatives or transactions related to sanctioned jurisdictions, persons or activities;
  • Shell banks;
  • Unlicensed CFD’s/Forex services;
  • Unlicensed or otherwise unauthorized Business, where such licensing or authorization is required by the law;
  • Unlicensed or otherwise unauthorized financial services (e.g., Hawala and other Informal Value Transfer Services, etc.);
  • Unlicensed or otherwise unauthorized gaming, gambling, casino, or betting services;
  • Unregistered charities;
  • Weapons, ammunition, rifles and related goods.

*Politically Exposed Persons (PEP) – natural persons who are or who have been entrusted with prominent public functions as well as their Immediate family members or Close associates of such persons.

Immediate family members – the spouse, the person with whom partnership has been registered (the ‘cohabitant’), parents, brothers, sisters, children, children’s spouses and children’s cohabitants.

Close associate: 1) a natural person who participates in the same legal person or an organization not having legal personality, or maintains any other business relationship, with the current or former PEP; 2) a natural person who has sole beneficial ownership of the legal person or an organization not having legal personality which has been set up or is operating for the de facto financial or any other private benefit of the person who is or was PEP.

2. Additional Restrictions for SWIFT payments

Restricted jurisdictions:

Afghanistan, Akrotiri, Bangladesh, Belarus, Burkina Faso, Burundi, Cambodia, Central African Republic, Chad, Christmas Island, Cocos (Keeling) Islands, Comoros, Congo, Crimea (region of Ukraine), Cuba, Democratic People’s Republic of Korea, Democratic Republic of Congo, Dhekelia, Donetsk (region of Ukraine), Equatorial Guinea, Eritrea, Eswatini, Falkland Islands, Guinea Bissau, Haiti, Honduras, Iran, Iraq, Lebanon, Libya, Luhansk (region of Ukraine), Madagascar, Mayotte, Mali, Myanmar, Mozambique, Nicaragua, Niger, Norfolk Island, Pakistan, Palestinian Territory, Paracel Islands, Paraguay, Pitcairn Islands, Russian Federation, Syria, Somalia, South Sudan, Sudan, Tajikistan, Turkmenistan, Uganda, Venezuela, Wallis and Futuna, Yemen, Zimbabwe.

These requirements are specific to the Product/Service and supplement the General Requirements. Where any inconsistency exists, the stricter or more conservative requirement shall apply.

3. Additional Restrictions for Multicurrency payments

Restricted jurisdictions:

Afghanistan, Albania, Belarus, Burundi, Republic of the Congo, Democratic Republic of the Congo, Crimea (region of Ukraine), Cuba, Donetsk region (Ukraine), Iran, Iraq, Kherson region (Ukraine), Lebanon, Liberia, Libya, Luhansk region (Ukraine), Macedonia, Myanmar, North Korea, Russian Federation, Somalia, South Sudan, Sudan, Syria, Venezuela, Yemen, Zaporizhzhia region (Ukraine).

Restricted industries list:

  • Binary option traders;
  • Cannabis or other drugs in any form;
  • Companies selling counterfeit or infringed products;
  • Companies selling, storing, or trading cryptocurrencies*;
  • File-sharing companies*;
  • Pharmacies selling copy products without proper authority approval, including e-pharmacies;
  • Pornography industry (dating pages* are acceptable);
  • Pyramid schemes in any form;
  • Shell banks;
  • Tobacco industry;
  • Weapons in any form, including dual-use goods;
  • Any other types of businesses involved in any form of criminal activity, and agents involved in cash-in/cash-out operations.

* Notwithstanding the above, the we may consider these industry and business types on a case by case exception basis.

These requirements are specific to the Product/Service and supplement the General Requirements. Where any inconsistency exists, the stricter or more conservative requirement shall apply.

4. Additional Restrictions for Correspondent relationship

In addition to clauses in I-III above, the following is applicable to Guru Pay relationship with Customers – Respondent Payment Service Providers. Where any inconsistency exists, the stricter or more conservative requirement shall apply.

Customer Risk – Risk appetite is limited to licensed or otherwise authorized Payment Service Providers (PSPs). PSPs that are engaged in other licensed or otherwise authorized financial services may be considered on a case-by-case basis. However, within the correspondent relationship, virtual IBANs (vIBANs) as a technical solution shall be offered exclusively for payment services activities. 

Conduct Risk – no Risk Appetite for:

  • Any breaches in applicable law, as well as instructions by the Bank of Lithuania or any other supervisory body.
  • Failures to conduct or incomplete End users (clients of the Customer)’ Due Diligence, Enhanced Due Diligence or Ongoing Due Diligence. The Customer is subject to collection, verification, analysis and evaluation of Due Diligence information of the End Users.
  • Sanctioned End Users, their beneficial owners, shareholders, representatives or transactions related to sanctioned jurisdictions, persons or activities.

 End User’s Risk – no Risk Appetite for:

  • PEPs*, Political parties or other similar organizations;
  • Financial institutions (banks, PSPs, MSBs, EMIs, PIs and similar);
  • End Users engaging in:
    • adult entertainment;
    • any illegal activities (including, but not limited to organized crime, drugs, weapons, money laundering, production and distribution of pornographic materials online etc.);
    • binary options trading & financial products in jurisdictions that do not have or require regulation/ licensing;
    • business with no license, where it is required by the law;
    • carbon trading;
    • cash for gold;
    • cheque cashing;
    • counterfeit goods;
    • development aid;
    • diamond merchants;
    • drugs, other psychotropic substances, drug paraphernalia and related;
    • Illegal goods;
    • licensed and supervised entities engaged in provision of CFD’s/Forex services outside EU/EEA;
    • licensed/otherwise authorized and supervised companies providing gaming, gambling, casino, or betting services outside EU/EEA, except from Curacao, Tobique, and Kahnawake;
    • medical marijuana/ cannabis (if over 0,2% THC);
    • MLM/pyramid schemes;
    • pawnbrokers;
    • shell banks;
    • unlicensed CFD’s/Forex services;
    • unlicensed or otherwise unauthorized financial services (e.g., Hawala and other Informal Value Transfer Services, etc.);
    • unlicensed or otherwise unauthorized gaming, gambling, casino, or betting services;
    • unregistered charities;
    • Virtual Asset Service Providers (VASPs) registered outside EU/EEA.
    • weapons, ammunition, rifles, and related goods. 

Geographic Risk – no Risk Appetite for:

End Users, their ultimate beneficial owners residing or registered in:

Transaction Risk – no Risk Appetite for:

  • Transactions involving Countries and Jurisdictions on) FATF “Black List”
  • Transactions involving Russia and Belarus.

5. Additional Restrictions for Acquiring Services

In addition to clauses in I-III above, the following is applicable to Guru Pay relationship with Customers – Merchants (Acquiring Services). Where any inconsistency exists, the stricter or more conservative requirement shall apply.

Customer Risk – no Risk Appetite for Customers – Merchants, engaged in:

  • Adult Content (Restricted) – all adult-related Merchant Category Codes (MCCs) are automatically declined;
  • Credit & Debt Services – credit repair services, debt consolidation counseling, identity theft protection, credit monitoring, or similar services;
  • Firearms & Weapons – sale or distribution of firearms, ammunition, explosives, switchblades, or military weapons. This includes parts and components;
  • High-Risk Gambling – Sports betting, online casinos, or gaming operations targeting US/Canadian residents (EU-licensed operations reviewed individually). Note: All gambling-related MCCs are automatically declined without exception;
  • Illegal Activities;
  • Investment Schemes – Forex trading platforms, cryptocurrency trading schemes, binary options, or other financial products targeting retail consumers without proper regulatory licensing. All cryptocurrency and forex trading MCCs are automatically declined;
  • Multi-Level Marketing Schemes – Pyramid schemes, Ponzi schemes, or Multi-Level Marketing (MLM) structures lacking tangible products or independent value propositions;
  • Pharmaceutical Products – unauthorized online pharmacies, prescription medication sales without proper licensing, or controlled substance distribution;
  • Recent Bankruptcy – Merchants in active bankruptcy proceedings or with bankruptcy history within the past three years;
  • Replica & Counterfeit Products – Merchants selling products designed to deceive consumers regarding brand ownership or authenticity;
  • Sanctions & Criminal History – Merchants subject to criminal investigation, listed on OFAC sanctions lists, PEP* databases, or involved in financial crime;
  • Suspicious Reputation Risk – any Merchant that Guru Pay determines poses unacceptable reputational risk, including those with negative media coverage or involvement in controversial activities;
  • Timeshares & Real Estate – timeshare sales, timeshare advertising, or vacation ownership schemes.

Automatically Declined High-Risk Merchant Categories:

  • MCC 4816 (Computer Network / Information Services: online network, data and file‑sharing services, often linked to cyberlockers).
  • MCC 5122 (Drugs, Drug Proprietaries, Druggist Sundries);
  • MCC 5912 (Drug Stores, Pharmacies) where operating in high‑risk online or cross‑border models (e.g. online pharmacies, unregulated supplements, cross‑border medicine distribution);
  • MCC 5962 (Direct Marketing – Travel);
  • MCC 5966 (Direct Marketing – Outbound Telemarketing);
  • MCC 5967 (Adult content and other inbound teleservices where content is adult);
  • MCC 5967 (Direct Marketing – Inbound Telemarketing);
  • MCC 5968/5969 and similar MCCs where business involves outbound or inbound telemarketing, continuity/negative‑option billing, or subscription models with elevated dispute and Refund risk;
  • MCC 5993 (Cigar Stores and Stands) and other tobacco merchants in cross‑border or online sales models;
  • MCC 6012 (Financial Institutions – Merchandise and Services: non‑face‑to‑face financial services, including some crypto and funding flows);
  • MCC 6051 (Non‑Financial Institutions – Foreign Currency, Non‑Fiat Currency including Cryptocurrency) for crypto exchanges, brokers and similar services;
  • MCC 6211 and similar MCCs representing high‑risk investment or trading platforms (especially card‑absent);
  • MCC 7273 (Dating and escort services);
  • MCC 7299 (Miscellaneous Personal Services: fortune telling, astrology and other sensitive personal services);
  • MCC 7299 where used for escort‑type or morally sensitive personal services;
  • MCC 7841 where used for adult content, and any other adult entertainment MCCs used for non‑face‑to‑face adult services;
  • MCC 7995 and related gambling/lottery/betting MCCs (including 7800, 7801, 7802 where applicable).