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:

  1. Management Commitment: Senior executive oversight with dedicated compliance officer responsibility

  2. Risk Assessment: Continuous evaluation of customers, transactions, and geographic exposure

  3. Internal Controls: Automated screening systems, escalation procedures, and comprehensive recordkeeping

  4. Testing and Auditing: Independent verification of compliance program effectiveness

  5. 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.

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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