Prohibited Activities and Restricted Transactions Policy
Effective Date: June 27, 2025 Policy Version: 1.0 Last Updated: June 27, 2025
Company Information
˚BrahmaFi Ltd. Registered Agent: QUIJANO & ASSOCIATES (BVI) LIMITED Address: Quijano Chambers, P.O. Box 3159, Road Town Tortola, VG1110 British Virgin Islands Country of Incorporation: British Virgin Islands
Purpose and Scope
BrahmaFi Ltd. ("BrahmaFi," "we," "us," or "our") is a credit card platform incorporated in the British Virgin Islands that partners with Rain for card issuance services. This Prohibited Activities and Restricted Transactions Policy ("Policy") establishes the activities, transactions, and jurisdictions that are prohibited or restricted when using BrahmaFi's services. This Policy is designed to ensure compliance with applicable laws and regulations, including but not limited to sanctions administered by the U.S. Office of Foreign Assets Control (OFAC), the UK Office of Financial Sanctions Implementation (OFSI), the European Union, and the United Nations Security Council.
This Policy applies to all BrahmaFi users, including consumer and corporate cardholders, and covers all transactions processed through our platform. Violations of this Policy may result in immediate account suspension, transaction blocking, asset freezing, or service termination as required by applicable law.
Regulatory Compliance Framework
BrahmaFi maintains a comprehensive five-pillar compliance framework based on OFAC standards:
Management Commitment: Senior executive oversight with dedicated compliance officer responsibility
Risk Assessment: Continuous evaluation of customers, transactions, and geographic exposure
Internal Controls: Automated screening systems, escalation procedures, and comprehensive recordkeeping
Testing and Auditing: Independent verification of compliance program effectiveness
Training and Communication: Ongoing staff education and clear reporting mechanisms
Legal Basis: This Policy implements requirements under the Bank Secrecy Act, USA PATRIOT Act, sanctions regulations, and international compliance obligations. Sanctions violations are subject to strict liability, meaning intent or knowledge of a violation is not required for enforcement action.
Prohibited Jurisdictions
Sanctioned Countries and Territories
BrahmaFi prohibits all transactions involving the following comprehensively sanctioned jurisdictions:
Cuba
Iran
North Korea (Democratic People's Republic of Korea/DPRK)
Syria
Crimea Region of Ukraine
Donetsk People's Republic Region of Ukraine
Luhansk People's Republic Region of Ukraine
Consumer Cardholder Restricted Countries
The following countries are restricted for consumer cardholder services:
Cuba, Democratic People's Republic of Korea (DPRK), Egypt, Iran, Myanmar, Nigeria, Russia, South Africa, Syria, Ukraine, Venezuela
Corporate Cardholder Restricted Countries
The following countries are restricted for corporate cardholder services:
Algeria, Angola, Bulgaria, Burkina Faso, Cameroon, Côte d'Ivoire, Croatia, Cuba, Democratic Republic of Congo, Democratic People's Republic of Korea (DPRK), Egypt, Haiti, Iran, Kenya, Lebanon, Mali, Monaco, Mozambique, Myanmar, Namibia, Nigeria, Philippines, Russia, South Africa, Senegal, South Sudan, Syria, Tanzania, Ukraine, Venezuela, Vietnam, Yemen
US State Restrictions
Consumer Cardholder Restricted States: Arizona, Delaware, Georgia, Idaho, Louisiana, Maryland, Missouri, Montana, Nevada, New Mexico, North Dakota, Ohio, Oregon, Rhode Island, South Dakota, Utah, Vermont, Washington, Wisconsin, Wyoming
Corporate Cardholder Restricted States: Nevada, New Mexico, North Dakota, South Dakota, Vermont
Note: Geographic restrictions are subject to change based on evolving regulatory requirements and risk assessments. BrahmaFi reserves the right to modify these restrictions as required by law or policy.
Prohibited Activities
Sanctioned Persons and Entities
BrahmaFi prohibits all transactions involving:
Individuals or entities on the OFAC Specially Designated Nationals (SDN) List
Individuals or entities on OFAC Consolidated Non-SDN Lists (including Foreign Sanctions Evaders, Sectoral Sanctions Identifications)
Individuals or entities on UK OFSI sanctions lists
Individuals or entities on EU Consolidated Sanctions Lists
Individuals or entities on UN Security Council Sanctions Lists
Any person or entity owned 50% or more by sanctioned individuals or entities (50% Rule)
Regulated and Illegal Activities
BrahmaFi prohibits the following activities:
Controlled Substances and Illegal Materials:
Sale, distribution, or promotion of illegal drugs, controlled substances, or drug paraphernalia
Unauthorized pharmaceutical sales requiring DEA or other regulatory licensing
Synthetic drugs, research chemicals, or substances designed to mimic illegal drugs
Weapons and Military Equipment:
Firearms, ammunition, explosives, or weapons of any kind
Military, police, or dual-use equipment without proper authorization
Weapon manufacturing components or instructions
Illegal Goods and Counterfeit Items:
Stolen merchandise or goods obtained through illegal means
Counterfeit, replica, or unauthorized copies of branded goods
Illegally imported or exported products
Items infringing patents, trademarks, copyrights, or other intellectual property rights
Gambling and Gaming:
Online casinos, sports betting, or games of chance
Lottery ticket sales or sweepstakes requiring consideration
Fantasy sports platforms (where prohibited by law)
Unlicensed gambling operations
Adult Content and Services:
Pornography, adult entertainment, or sexually explicit materials
Escort services, prostitution, or sex trafficking
Dating services that facilitate prostitution
Financial Services Violations
BrahmaFi prohibits the following financial activities:
Fraudulent and Deceptive Practices:
Ponzi schemes, pyramid schemes, or multi-level marketing programs
"Get rich quick" schemes or unrealistic investment promises
Advance fee fraud or advance payment scams
Identity theft, account takeover, or unauthorized access to financial accounts
Unlicensed Financial Services:
Money transmission without proper licensing
Unlicensed investment advisory services
High-risk, high-interest rate lending (payday loans)
Debt collection services without proper authorization
Cryptocurrency exchanges or dealers without regulatory compliance
Money Laundering and Financial Crimes:
Structuring transactions to evade reporting requirements
Creating or using accounts to facilitate money laundering
Terrorist financing or providing material support to terrorist organizations
Transactions designed to circumvent sanctions or other legal restrictions
Intellectual Property Infringement
BrahmaFi prohibits activities involving:
Unauthorized distribution of copyrighted music, movies, software, or digital content
Sale of counterfeit designer goods, luxury items, or branded merchandise
Patent infringement or unauthorized use of proprietary technology
Trademark violations or unauthorized use of protected brand names
Trade secret theft or unauthorized disclosure of confidential information
Violent and Hateful Activities
BrahmaFi prohibits:
Promoting, supporting, or perpetrating violence or physical harm against individuals or groups
Hate speech or discrimination based on race, religion, ethnicity, nationality, disability, gender, sexual orientation, gender identity, or immigration status
Terrorist activities, extremist content, or materials promoting violence
Harassment, stalking, or intimidation of individuals
Content or activities that glorify or promote self-harm or suicide
Platform Misuse and Unauthorized Activities
BrahmaFi prohibits:
Providing false, misleading, or deceptive information during account opening or transaction processing
Using BrahmaFi services for undisclosed or unauthorized business purposes
Circumventing or attempting to circumvent BrahmaFi's compliance controls or monitoring systems
Creating multiple accounts to evade restrictions or limitations
Using automated systems or bots to manipulate BrahmaFi's services
Restricted Activities Requiring Additional Documentation
The following activities may be restricted or require enhanced due diligence and additional documentation:
Financial Services Providers:
Banks, credit unions, or other depository institutions
Securities brokers, dealers, or investment advisors
Money service businesses or money transmitters
Insurance companies or insurance intermediaries
Investment funds, hedge funds, or asset management companies
Cryptocurrency and Digital Asset Businesses:
Cryptocurrency exchanges, dealers, or wallet providers
Digital asset investment platforms
Blockchain technology companies handling digital assets
Initial coin offering (ICO) or token sale platforms
High-Risk Industries:
Pharmaceutical companies with controlled substance licenses
Travel services, especially to high-risk jurisdictions
Precious metals dealers or coin/currency dealers
Art dealers, auction houses, or luxury goods merchants
Cash-intensive businesses without adequate controls
Note: BrahmaFi reserves the right to request additional documentation, impose transaction limits, or decline services for any restricted activity based on risk assessment.
Compliance Monitoring and Enforcement
Screening and Monitoring Procedures
BrahmaFi implements comprehensive compliance monitoring including:
Real-time Screening: All customers and transactions are screened against applicable sanctions lists before processing
Ongoing Monitoring: Continuous surveillance of customer activities and transaction patterns
Enhanced Due Diligence: Additional verification for high-risk customers, jurisdictions, or transactions
Beneficial Ownership Identification: Verification of ultimate beneficial owners for corporate accounts
Enforcement Actions
BrahmaFi reserves the right to take the following actions for Policy violations:
Transaction Blocking: Immediate suspension of transactions pending investigation
Account Restriction: Limitation of account access or transaction capabilities
Asset Freezing: Freezing of funds as required by sanctions regulations
Account Termination: Permanent closure of accounts for serious violations
Regulatory Reporting: Filing of Suspicious Activity Reports (SARs) or sanctions violations reports as required by law
Updates and Modifications
This Policy is subject to change without prior notice as regulatory requirements evolve or BrahmaFi's risk assessment changes. Prohibited activities and jurisdictions lists are updated in real-time as required by sanctions authorities and other regulatory bodies.
Users are responsible for reviewing current Policy terms and ensuring their own compliance with applicable laws. Continued use of BrahmaFi's services after any Policy update constitutes acceptance of the revised terms.
Legal Disclaimers and Liability Limitations
Compliance Safe Harbor
BrahmaFi implements its compliance policies and procedures in good faith based on current regulatory guidance and industry best practices. BrahmaFi and its employees are protected by applicable safe harbor provisions for good faith compliance with sanctions regulations and suspicious activity reporting requirements.
Limitation of Liability
BrahmaFi shall not be liable for any losses or damages arising from compliance with applicable laws, including but not limited to the freezing of funds, blocking of transactions, or termination of services as required by law. Users acknowledge that sanctions lists and regulatory requirements change frequently, and users are independently responsible for ensuring their own compliance with applicable laws and regulations.
Indemnification
Users agree to indemnify and hold harmless BrahmaFi from any claims, damages, or losses arising from users' non-compliance with applicable laws, regulations, or this Policy.
Governing Law and Jurisdiction
This Policy shall be governed by and construed in accordance with the laws of the British Virgin Islands, without regard to its conflict of law principles. Any disputes arising under this Policy shall be subject to the jurisdiction of the courts of the British Virgin Islands.
Regulatory Compliance: As a BVI-incorporated entity providing financial services, BrahmaFi complies with applicable British Virgin Islands financial services regulations in addition to international sanctions requirements. BrahmaFi also adheres to the regulatory requirements of jurisdictions where its services are offered.
Contact Information
For questions regarding this Policy or to report suspected violations:
BrahmaFi Ltd. Quijano Chambers P.O. Box 3159, Road Town Tortola, VG1110 British Virgin Islands
Compliance Department Email: [email protected] Business Hours: Monday - Friday, 9:00 AM - 5:00 PM (UTC-4)
Suspicious Activity Reporting Email: [email protected] Phone: Available during business hours
IMPORTANT NOTICE: This Policy incorporates requirements from multiple regulatory authorities and is designed to ensure comprehensive compliance with applicable laws. Sanctions regulations are subject to strict liability, and violations can result in significant civil and criminal penalties. Users should consult with qualified legal counsel regarding their specific compliance obligations. This document does not constitute legal advice and should not be relied upon as a substitute for consultation with qualified legal professionals regarding specific situations or regulatory requirements.
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