Acceptable Use Policy

1. Scope

This Acceptable Use Policy ("AUP") supplements the Sintrio Terms of Service and reflects the operating rules of the major card networks (Visa, Mastercard, American Express, Discover), United States anti-money laundering ("AML") and counter-terrorist financing ("CFT") regulations, United States sanctions law administered by the Office of Foreign Assets Control ("OFAC"), and other applicable laws and regulations. Any violation of this AUP may result in suspension of the Services, holds on funds, permanent account closure, recovery of damages, and referral to law enforcement.

2. Prohibited Activities

You may not use the Sintrio Services in connection with any activity that is illegal under United States federal, state, or local law, or under the law of any jurisdiction in which you operate or transact. By way of example, and without limitation, you may not:

• engage in money laundering, structuring, or any transaction intended to disguise the source, destination, or beneficial owner of funds;
• finance terrorism or any designated terrorist organization;
• evade taxes or assist others in tax evasion;
• process payments for the sale of illegal drugs, controlled substances outside of an applicable license, weapons (including ammunition or explosives) in violation of applicable law, or human trafficking;
• infringe upon intellectual property rights, including counterfeit goods, pirated software, and unauthorized reproductions of copyrighted material;
• transact with any individual, entity, or country subject to OFAC sanctions, including those listed on the Specially Designated Nationals and Blocked Persons List, or with comprehensively sanctioned jurisdictions including Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine.

3. Prohibited Business Categories

The following business categories are categorically prohibited from using the Sintrio Services:

• adult content, pornography, escort services, and sexually oriented digital content;
• unlicensed gambling, sports betting, lotteries, sweepstakes, and games of chance;
• unregistered financial services, including unlicensed money transmission, unlicensed broker-dealer activity, and unlicensed lending;
• unlicensed cryptocurrency exchanges or wallet providers (regulated cryptocurrency platforms may be onboarded only with prior approval, enhanced KYB review, and a custom risk framework);
• regulated substances sold without appropriate licenses or age controls, including alcohol without age verification, cannabis and CBD products without a state license in compliance with US federal and state law, and prescription pharmaceuticals;
• weapons, ammunition, and explosives unless sold pursuant to a valid federal firearms license and compliant with all applicable laws;
• DRM circumvention tools, jailbreak utilities, and unauthorized streaming devices;
• endangered species, ivory, and any wildlife products prohibited under the Endangered Species Act or CITES;
• pyramid schemes, multi-level marketing programs with guaranteed returns, and Ponzi schemes;
• miracle health products, unverified medical cures, fraudulent supplements, and weight-loss schemes;
• hate speech, incitement to violence, doxxing services, harassment platforms, and spyware or stalkerware;
• any other business category determined by Sintrio, in its sole discretion, to present unacceptable legal, financial, or reputational risk.

4. High-Risk Categories

The following categories are not prohibited but require enhanced KYB review, a customized reserve structure, and bespoke pricing. Sintrio reserves the right to decline an application or to impose additional controls at its discretion:

• long-haul travel and ticketing (airlines, cruise lines, multi-destination tour operators);
• subscription continuity merchants and negative-option billing models;
• online coaching, education, and training platforms with multi-month curricula;
• crowdfunding platforms, donation platforms, and charitable fundraising;
• multi-vendor marketplaces and on-demand platforms;
• verticals with statistically elevated chargeback rates as defined by card network monitoring programs (above 0.9% on Visa or 1.5% on Mastercard).

5. Platform Behavior

You agree to use the Sintrio Services in good faith and in accordance with our published documentation. You may not:

• maintain multiple accounts to circumvent suspensions, reserve requirements, or risk limits;
• abuse the Sintrio API, including by exceeding rate limits, scraping data, or attempting to enumerate resources;
• introduce malware, viruses, worms, or other malicious code into the Services;
• conduct card testing or any activity designed to validate stolen card credentials;
• manipulate fraud signals, dispute evidence, or other risk inputs;
• act as an unauthorized aggregator, factoring agent, or third-party encasher of payments on behalf of any other party without Sintrio's prior written consent;
• attempt to reverse engineer, decompile, or extract proprietary information from the Services.

6. Reporting Abuse

If you become aware of any actual or suspected violation of this AUP, please report it promptly to abuse@sintrio.io. Reports may be made anonymously. Sintrio investigates all credible reports of abuse.

7. Enforcement

Sintrio enforces this AUP rigorously. Depending on the nature and severity of a violation, enforcement actions may include, individually or in combination: warning and request for remediation; suspension of processing capability; placement of a reserve hold on Customer funds; permanent account closure with forfeiture of disputed amounts; recovery of damages, fees, and penalties; reporting to card networks for inclusion on the MATCH (Merchant Alert To Control High-Risk Merchants) list; reporting to FinCEN, OFAC, the Federal Bureau of Investigation, state attorneys general, or other competent authorities; and civil or criminal litigation. Sintrio reserves all rights and remedies available at law or in equity.

8. Contact

For questions about this Acceptable Use Policy, or to request clarification regarding a specific business model:

Sintrio LLC — Compliance
Abuse reports: abuse@sintrio.io
General: contact@sintrio.io
2029 Black Jack Loop Num 3574
Cheyenne, WY 82001-7282, USA
Phone: +1 (319) 323-7348