Activity Risk Assessment – Explicative Note

Activities Risk Assessment

Prohibited activities

BANKCHAIN will not deal with clients who are involved in any unlawful or fraudulent activities.

Moreover, by policy, BANKCHAIN prohibits the onboarding of clients who are active in the following areas:

Industry or activity sector	Example of underlying activities
Nuclear industry	§ Uranium, Thorium and Plutonium extraction § Transformation of nuclear material
Any activity linked to weapons, firearms and ammunition	§ Manufacturing § Trade, import-export
Any activity linked to explosives* or other explosive substances * For example: C4, dynamite, TNT, gunpowder, detonators, mines, RDX, Torpex, Tovex, Grenades, etc.	§ Manufacturing § Trade, import-export
Military combat vehicles manufacturing	§ Battle tanks § Infantry combat vehicles § Military combat aircraft or ships § Armored combat support vehicles
Gambling industry	§ Casinos § Sports, races and e-sports betting § Online gambling
Gaming industry	 Gaming loot boxes
Sex industry	§ Pornography, diffusion and production of sexthemed visual content § Phone sex and related sexual services § Prostitution, escort agencies and assimilated sex workers organization § Massage parlors
Surrogacy	 Surrogacy services
Precious metals* industry * For example: Gold, Silver, Platinum, Palladium, Ruthenium, Rhodium, Iridium, Osmium, Rhenium, Indium	§ Mining, extraction § Production
Precious and high-value gemstones* industry * For example: Diamond, Ruby, Sapphire, Emerald, Tanzanite, Opal, Beryl, Musgravite, Alexandrite, Jadeite etc.	§ Mining, extraction § Sale, import-export of the gross material (e.g. rough diamonds)
Activities against animal welfare	§ Animal testing for cosmetic purposes § Trade of skins, ivory and other parts of protected animals
Lead generation and call center activities	§ Leads generation § Leads sale § Outbound telemarketing § Centralized office used for receiving or transmitting a large volume of enquiries by telephone (Call center)
Soft drugs (legalized or tolerated)	 Trade of soft drugs (e.g. marijuana in coffeeshops in Holland)
Industry or activity sector	Example of underlying activities
Trusts	 Trusts, fiducies and similar arrangements
Certain activities in the cryptocurrency sector	 Any activity linked to anonymous cryptocurrencies* or cryptocurrencies favoring anonymity of their owner *XMR, ZEC, PIVX, KMD, XVG, Zcoin, NAV, ZEN, ONION, XSPEC, etc.
Certain activities in the banking sector	§ Shell banks § Offshore banks § Bank authorizing nesting accounts or downstream correspondent clearing § Banks offering “passing-through” account services § Bearer security issuers § Online payday lenders
Other controversial activities	§ Manufacturing, sale or distribution of any prohibited or illegal good or service or an activity that requires a governmental license where the client lacks such a license § Manufacturing, sale or distribution of any material that promotes violence or hatred § Manufacturing, sale or distribution of goods or services that violate the intellectual property rights of a third party § Ponzi-schemes or pyramid selling

While this list is representative, it is not exhaustive, and BANKCHAIN reserves its right to deny its services to any client who exceeds our risk appetite.

If you are uncertain as to whether an activity sector is prohibited, or if you have any questions about the application of this activity risk matrix, please contact the Compliance Department at contact@global-bankchain.com

Furthermore, if you notice any legal activity that is not described here that may pose a reputational risk to BANKCHAIN, please inform the Compliance department at contact@global-bankchain.com

High risk activities

Additionally, BANKCHAIN acknowledges that some sectors are more likely to be associated with a higher risk of money laundering or terrorist financing or fraud. For clients operating in these sectors, BANKCHAIN will apply a higher risk score.

Industry or activity sector	Example of underlying activities
Cash-intensive sectors	§ Restaurants, fast foods, take away § Hotels, hostels, resorts § Nightclubs § Bars, pubs, cafés, tea/coffee shops, playing rooms § Taxis § Beauty institutes and parlors § Spas § Hairdressing § Laundry activity
Real Estate sector	§ Real estate promotion § Real estate construction § Real estate agencies
Construction sector	§ Manufacture and sale of construction machinery and tools § Road, railways and telecom networks building
Art industry	§ Artists § Galleries
Pharmaceutical industry	§ Pharmaceuticals manufacturing § Pharmaceuticals trade, import-export § Sale or distribution of prescription medications
Covid-19 related services	§ Manufacture and trade of masks and equipment; § Manufacture and trade of personal-use tests
Chemical industry	§ Trade, import-export § Distribution
Raw materials* industry *metals, gas, other minerals, hydrocarbons	§ Mining § Trade, import-export
Petroleum industry	§ Extracting § Trade, import-export
Tobacco industry	§ Manufacturing § Trade, import-export § E-liquid, CBD § CBD and cannabis derivative shops § CBD and cannabis derivative import-export
Travel industry	 Travel and tourism agencies, tour operators
Luxury industry	§ Luxury resorts, hotels § Manufacture, sale, import-export of luxury items*

Industry or activity sector	Example of underlying activities
	*For example: leathers, furs, jewelry, watches, yachts, high end cosmetics, perfumes, high-end spirits, designers’ creations, haute couture, etc.
Horse breeding	 Horse or other equines breeding
Electronic sector	 Manufacture, sale, repair of electronic components, including telephones, computers and household appliances
IT sector	§ IT development, programming § IT consulting, audit
Vehicles sector	§ Trading second hands vehicles § Vehicle repairing § Vehicles rental
Aeronautical and space construction	 Aerospace manufacturers
Defense activities	 Administration, supervision and management of national defense activities  Military logistics
Physical security sector	§ Physical surveillance with security guards § Video surveillance and assimilated § Drones
3D Printing	§ Trade of 3D printers § 3D printing services § 3D metal printing § Industrial 3D printing
Renewable energies* sector *Solar, biomass, wind, water, wood, geothermal, ocean tides	§ Patent distribution § Renewable energy transport and distribution
Wastes treatment activities	§ Collection, recycling and treatment of waste, wreck § Wholesale and sorting of wastes and debris
Cleaning and facility services industry	§ Cleaning services  Facilities services § Industrial and domestic cleaning
Governmental activities	§ Embassies, Consulates § Diplomatic missions
Holding companies	 Holding companies
Legal services and accounting activities	§ Domiciliation companies § Lawyers and legal counsels § Attorneys § Notaries
Non-profit activities	§ Charities § Private foundations
Financial sector	§ Banks and neo-banks: retail & business, private, investment § Payment institutions § Investment companies, pension funds  Insurance
Cryptocurrency sector	 Any activity linked to cryptocurrencies that is not prohibited* *Refer to the cryptocurrency policy

If you are uncertain as to whether an activity sector is high risk, or if you have any questions about the application of this activity risk matrix, please contact the Compliance Department at contact@global-bankchain.com.