Money Laundering

You are independently responsible for complying with all applicable laws in all of your actions related to your use of LT’s services, regardless of the purpose of the use. In addition, you must adhere to the terms of this Acceptable Use Policy. Violation of this Acceptable Use Policy constitutes a violation of your LT User Agreement (see Restricted Activities andHolds section of the User Agreement).

Prohibited Activities:You may not use the LT service for activities that:

1. violate any law, statute, ordinance or regulation.
2. relate to transactions involving (a) narcotics, steroids, certain controlled substances or other products that present a risk to consumer safety, (b) drug paraphernalia, (c) cigarettes, (d) items that encourage, promote, facilitate or instruct others to engage in illegal activity, (e) stolen goods including digital and virtual goods, (f) the promotion of hate, violence, racial or other forms of intolerance that is discriminatory or the financial exploitation of a crime, (g) items that are considered obscene, (h) items that infringe or violate any copyright, trademark, right of publicity or privacy or any other proprietary right under the laws of any jurisdiction, (i) certain sexually oriented materials or services, (j) ammunition, firearms, or certain firearm parts or accessories, or (k) certain weapons or knives regulated under applicable law.
3. relate to transactions that (a) show the personal information of third parties in violation of applicable law, (b) support pyramid or ponzi schemes, matrix programs, other “get rich quick” schemes or certain multi-level marketing programs, (c) are associated with purchases of annuities or lottery contracts, lay-away systems, off-shore banking or transactions to finance or refinance debts funded by a credit card, (d) are for the sale of certain items before the seller has control or possession of the item, (e) are by payment processors to collect payments on behalf of merchants, (f) are associated with the sale of traveler’s checks or money orders, (g)involve currency exchanges or check cashing businesses, (h) involve certain credit repair, debt settlement services, credit transactions or insurance activities, or (i) involve offering or receiving payments for the purpose of bribery or corruption.
4. involve the sales of products or services identified by government agencies to have a high likelihood of being fraudulent.
5. relate to transactions involving any activity that requires approval without having obtained said approval.

Activities Requiring Approval: LT requires approval to accept payments for certain services.If you have questions about obtaining an approval or opening a new Lock Trust Business account that offers services requiring approval, please contact our Sales team.

Violations of the Acceptable Use Policy: We encourage you to report violations of this Acceptable Use Policy to LT immediately. If you have a question about whether a type of transaction may violate the Acceptable Use Policy please contact us.

Restricted Activities: In connection with your use of our websites, your LT account, the LT services, or in the course of your interactions with LT, other LT customers, or third parties, you must not:

• Breach this user agreement, the LT Acceptable Use Policy, or any other agreement between you and us.
• Violate any law, statute, ordinance, or regulation (for example, those governing financial services, consumer protections, unfair competition, anti-discrimination or false advertising).
• Infringe LT’s or any third party’s copyright, patent, trademark, trade secret or other intellectual property rights, or rights of publicity or privacy.
• Sell counterfeit goods.
• Act in a manner that is defamatory, trade libelous, threatening or harassing.
• Provide false, inaccurate or misleading information.
• Send or receive what we reasonably believe to be potentially fraudulent or unauthorized funds.
• Refuse to cooperate in an investigation or provide confirmation of your identity or any information you provide to us.
• Attempt to “double dip” during the course of a dispute by receiving or attempting to receive funds from both LT and the seller, bank or card issuer for the same transaction.
• Control an account that is linked to another account that has engaged in any of these restricted activities.
• Conduct your business or use the LT services in a manner that results in or may result in:
  • Complaints.
  • Requests by buyers (either filed with us or card issuers) to invalidate payments made to you.
  • Fees, fines, penalties or other liability or losses to LT, other LT customers, third parties or you.
• Use your LT account or the LT services in a manner that LT, Visa, MasterCard, American Express, Discover or any other electronic funds transfer network reasonably believes to be an abuse of the card system or a violation of card association or network rules.
• Allow your LT account to have a balance reflecting an amount owing to us.
• Provide yourself a cash advance from your credit card (or help others to do so).
• Access the LT services from a country that is not included on our Excluded Jurisdictions list.
• Take any action that imposes an unreasonable or disproportionately large load on our websites, software, systems (including any networks and servers used to provide any of the LT services) operated by us or on our behalf or the LT services.
• Facilitate any viruses, trojan horses, malware, worms or other computer programming routines that attempts to or may damage, disrupt, corrupt, misuse, detrimentally interfere with, surreptitiously intercept or expropriate, or gain unauthorized access to any system, data, information or LT services.
• Use an anonymizing proxy; use any robot, spider, other automatic device, or manual process to monitor or copy our websites without our prior written permission; or use any device, software or routine to bypass our robot exclusion headers.
• Interfere or disrupt or attempt to interfere with or disrupt our websites, software, systems (including any networks and servers used to provide any of the LT services) operated by us or on our behalf, any of the LT services or other users’ use of any of the LT services.
• Take any action that may cause us to lose any of the services from our Internet service providers, payment processors, or other suppliers or service providers.
• Use the LT services to test credit card behaviors.
• Circumvent any LT policy or determinations about your LT account such as temporary or indefinite suspensions or other account holds, limitations or restrictions, including, but not limited to, engaging in the following actions: attempting to open new or additional LT account(s) when an account has a negative balance or has been restricted, suspended or otherwise limited; opening new or additional LT accounts using information that is not your own (e.g. name, address, email address, etc.); or using someone else’s LT account.
• Harass and/or threaten our employees, agents, or other users.
• Abuse (as either a buyer or seller) of our online dispute resolution process and/or LT Buyer Protection.
• Cause us to receive a disproportionate number of claims that have been closed in favor of the claimant regarding your LT account or business.
• Have a credit score from a credit reporting agency that indicates a high level of risk associated with your use of the LT services.
• Use a credit card with your LT account to provide yourself with a cash advance (or help others to do so).
• Disclose or distribute another user’s information to a third party, or use such information for marketing purposes unless you receive the user’s express consent to do so.
• Send unsolicited email to a user or use the LT services to collect payments for sending, or assisting in sending, unsolicited email to third parties.
• Copy, reproduce, communicate to any third party, alter, modify, create derivative works, publicly display or frame any content from the LT website(s) without our or any applicable third party’s written consent.
• Reveal your account password(s) to anyone else, nor may you use anyone else’s password. We are not responsible for losses incurred by you including, without limitation, the use of your account by any person other than you, arising as the result of misuse of passwords.
• Do, or omit to do, or attempt to do or omit to do, any other act or thing which may interfere with the proper operation of the LT service or activities carried out as part of LT services or otherwise than in accordance with the terms of this user agreement.
• Request or send a personal transaction payment for a commercial transaction.
• Allow your use of the LT service to present to LT a risk of non-compliance with LT’s anti-money laundering, counter terrorist financing and similar regulatory obligations (including, without limitation, where we cannot verify your identity or you fail to complete the steps to lift your sending, receiving or withdrawal limit or where you expose LT to the risk of any regulatory fines by European, US or other authorities for processing your transactions).
• Integrate or use any of the LT services without fully complying with all mandatory requirements communicated to you by way of any integration or programmers’ guide or other documentation issued by LT from time to time.
• Advertise, promote, introduce or describe LT Credit or any LT co-branded credit based payment instrument to your customers without: (1) obtaining the necessary regulatory permission to do so in advance; and (2) the prior written permission of LT and (if not LT) the issuer of the credit to do so.
• Suffer (or cause us to determine that there is a reasonable likelihood of) a security breach of your website or systems that could result in the unauthorized disclosure of customer information.

You agree that engaging in the above restricted activities diminishes your or our other customers’ safe access and/or use of your account and our services generally.

Actions We May Take if You Engage in Any Restricted Activities: If we believe that you’ve engaged in any of these activities, we may take a number of actions to protect LT, its customers and others at any time in our sole discretion. The actions we may take include, but are not limited to, the following:

• Terminate this user agreement, limit your account, and/or close or suspend your account, immediately and without penalty to us.
• Refuse to provide the LT services to you in the future.
• At any time and without liability, suspend, limit or terminate your access to our websites, software, systems (including any networks and servers used to provide any of the LT services) operated by us or on our behalf, your LT account or any of the LT services, including limiting your ability to pay or send money with any of the payment methods linked to your LT account, restricting your ability to send money or make withdrawals.
• Hold your money to the extent and for so long as reasonably needed to protect against the risk of liability. You acknowledge that, as a non-exhaustive guide:

• LT’s risk of liability in respect of card-funded payments that you receive can last until the risk of a charge back closing in favor of the payer/buyer (as determined by card scheme rules) has passed. This depends on certain factors, including, without limitation:
  1. The type of goods or services for which you receive payment.
  2. The time frame for delivery of the goods or performance of the services for which you receive payment (e.g. sales of event tickets months in advance of the event date can present a higher and more enduring risk of charge backs than sales of most other items or services).
• LT’s risk of liability in respect of a claim or dispute arising from a payment that you receive can last for the time that it takes for the parties to close the claim or dispute and all appeals associated with that claim or dispute in accordance with LT Buyer Protection.
• LT’s risk of liability in respect of any event of insolvency that you suffer can last for as long as and to the extent that laws applicable to your insolvency restrict LT from taking legal action against you.
• If you allow your LT account to have a balance reflecting an amount owing to LT, LT’s risk of liability can last for the time and to the extent that you owe that amount to LT.

• Block your LT account and/or hold any funds in the reserve account (including, without limitation, for more than 180 days if so required by LT, where LT’s rights arise from your engagement in the restricted activity).
• Refuse any particular payment transaction at any time for any reason and will only be required to make available the fact of the refusal and the reasons for the refusal and how you may resolve the problem, where possible, upon request and provided it is not prohibited by law.
• Reverse a payment (including, if appropriate, to the sender’s funding source).
• Take legal action against you.
• Suspend your eligibility for LT Buyer Protection and/or LT Seller Protection (including in retrospect).
• Contact third parties and disclose details of the restricted activities in the manner set out in our Privacy Statement.
• Request or update inaccurate information you provided us.
• Request information or documents from you in order to verify your identity and/or with regard to the goods or services you provided based on a transaction.
• If you’ve violated our Acceptable Use Policy, then you’re also responsible for damages to LT caused by your violation of this policy.

If you use your LT account primarily for the purposes of your trade, business, craft or profession and you violate the Acceptable Use Policy, then:

• In addition to being subject to the above actions you will be liable to LT for the amount of LT’s damages caused by your violation of the Acceptable Use Policy.

• You acknowledge and agree that USD 2,500.00 (or the prevailing equivalent in the currency of the country in which you reside) per violation of the Acceptable Use Policy is:
  • A reasonable minimum estimate of LT’s actual damages including but not limited to, internal administrative costs incurred by LT to monitor and track violations, damage to LT’s brand and reputation, and penalties imposed upon LT by its business partners resulting from a user’s violation considering all currently existing circumstances, including the relationship of the sum to the range of harm to LT that reasonably could be anticipated.
  • Reasonable and proportionate in its application to the provision of the services to you.
  • Necessary, but no more than sufficient, to protect LT’s legitimate interest in your compliance with the Acceptable Use Policy.

• LT may deduct such damages directly from any existing balance in any LT account you control.

Unless otherwise directed by us, you must not use or attempt to use your account while it is suspended or has been closed. You must ensure that all agreements with sellers or other third parties that involve third party initiated payments (including billing agreement payments) set up from your account are cancelled immediately upon the termination, suspension or closure of your account. You remain liable under this user agreement in respect of all charges and other amounts incurred through the use of your account at any time, irrespective of termination, suspension or closure.