Effective from: February 25, 2025

Terms Of Business

1. About Us
1.1 Our legal name is SPOYNT Ltd (“SPOYNT”). Our registered office is at:
71-75 Shelton Street, London, WC2H 9JQ, United Kingdom
Company registration number: 14156599

1.2 SPOYNT Ltd is registered with the UK Financial Conduct Authority under FRN 903071 as an EMD Agent, with rights to distribute or redeem electronic money (e-money) and provide certain payment services on behalf of an e-money institution, Noveba Limited, FRN 900924.

1.3 You may contact us at any time by writing to us at the above address or sending an email to our Support Team (payment@spoynt.com). Contact details are available in the FAQ section of our website.
2. Regulated Activities
2.1 SPOYNT Ltd operates as an EMD Agent with rights to distribute or redeem electronic money (e-money) and provide certain payment services on behalf of an e-money institution.
  • FRN: 903071 (https://register.fca.org.uk/s/firm?id=0014G0000323qkeQAA )
  • Regulator: Financial Conduct Authority
  • Effective From: 01/04/2021
Principal Firm Details:
  • Name: Noveba Limited
  • Company Number: 11610200
  • Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, UNITED KINGDOM
  • Companies House Ref: https://beta.companieshouse.gov.uk/company/11610200
  • Type: EMD
  • FRN: 900924
  • Current status: Authorised Electronic Money Institution A firm that we have given permission to issue electronic money (e-money) and provide payment services.
  • Regulator Name: Financial Conduct Authority
  • Effective From: 16/08/2019
  • Reference: https://register.fca.org.uk/s/firm?id=0010X00004JBGVaQAP
3. Codes of Conduct
3.1 SPOYNT Ltd is subject to legislative requirements under the Electronic Money Regulations 2011 and the Payment Services Regulations 2017.
4. Fees and Charges
4.1 SPOYNT Ltd applies fees and charges to its products and services. Details are available in the Fees section of our website. These fees may be amended periodically.
5. Data Protection Notice
5.1 The personal information requested from you is required for account opening checks. We will process your data in compliance with the Data Protection Act 2018.
6. Complaints
6.1 You may submit complaints via:
  • In writing (letter or email)
  • Verbally
6.2 Your complaint will be investigated by SPOYNT Ltd, and an acknowledgment letter will be sent to you. If unresolved within 35 business days, you may escalate your complaint to the Financial Ombudsman Service, Exchange Tower, London, E14 9SR.
7. Changes to Terms of Business
7.1 Any material changes will be notified via email, website notices, or the app.
Appendix A – List of Prohibited Jurisdictions
Customers and/or transactions that have a direct and clear link (e.g., entity/asset ownership, UBO, business ties, or other strong relationships) to the following jurisdictions are subject to the following service supply status:

Country / Territory

Client Account Opening & Maintenance

Transactions (Incoming / Outgoing / Exchange)

Notes

Abkhazia

PROHIBITED

PROHIBITED


Afghanistan

PROHIBITED

PROHIBITED


Andorra

ALLOWED*

ALLOWED*

Subject to Enhanced Due Diligence (EDD) on a case-by-case basis

Anguilla

PROHIBITED

PROHIBITED


Antigua and Barbuda

PROHIBITED

PROHIBITED


Armenia

PROHIBITED

ALLOWED*

Subject to EDD on a case-by-case basis

Azerbaijan

PROHIBITED

ALLOWED*

Subject to EDD on a case-by-case basis

Aruba

PROHIBITED

PROHIBITED


Bahamas

PROHIBITED

PROHIBITED


Bahrain

PROHIBITED

PROHIBITED


Barbados

PROHIBITED

PROHIBITED


Belarus

PROHIBITED

PROHIBITED


Belize

PROHIBITED

PROHIBITED


Bermuda

PROHIBITED

PROHIBITED


British Virgin Islands

PROHIBITED

PROHIBITED


Burundi

PROHIBITED

PROHIBITED


Cayman Islands

PROHIBITED

PROHIBITED


Central African Republic

PROHIBITED

PROHIBITED


Cook Islands

PROHIBITED

PROHIBITED


Cuba

PROHIBITED

PROHIBITED


Democratic Republic of the Congo

PROHIBITED

PROHIBITED


Djibouti

PROHIBITED

PROHIBITED


Egypt

PROHIBITED

PROHIBITED


Eritrea

PROHIBITED

PROHIBITED


Ethiopia

PROHIBITED

PROHIBITED


Gaza Strip

PROHIBITED

PROHIBITED


Guatemala

PROHIBITED

PROHIBITED


Guinea

PROHIBITED

PROHIBITED


Haiti

PROHIBITED

PROHIBITED


Iran

PROHIBITED

PROHIBITED


Iraq

PROHIBITED

PROHIBITED


Ivory Coast (Côte D'Ivoire)

PROHIBITED

PROHIBITED


Jamaica

PROHIBITED

PROHIBITED


Kenya

PROHIBITED

PROHIBITED


Kuwait

PROHIBITED

PROHIBITED


Lebanon

PROHIBITED

ALLOWED*

Subject to EDD on a case-by-case basis

Liberia

PROHIBITED

PROHIBITED


Libya

PROHIBITED

PROHIBITED


Macau

PROHIBITED

PROHIBITED


Maldives

PROHIBITED

PROHIBITED


Mali

PROHIBITED

PROHIBITED


Mauritius

PROHIBITED

PROHIBITED


Moldova (including Transnistria)

PROHIBITED

PROHIBITED


Monaco

PROHIBITED

PROHIBITED


Myanmar (Burma)

PROHIBITED

PROHIBITED


North Korea

PROHIBITED

PROHIBITED


Pakistan

PROHIBITED

PROHIBITED


Panama

PROHIBITED

PROHIBITED


Russian Federation

PROHIBITED

PROHIBITED


Seychelles

PROHIBITED

PROHIBITED


Somalia

PROHIBITED

PROHIBITED


South Ossetia

PROHIBITED

PROHIBITED


Sudan

PROHIBITED

PROHIBITED


Syria

PROHIBITED

PROHIBITED


Ukraine (excluding Donetsk & Luhansk regions)

ALLOWED*

ALLOWED*

Subject to EDD on a case-by-case basis, excluding war-affected territories

Ukraine – Donetsk & Luhansk region territories

PROHIBITED

PROHIBITED


United Arab Emirates

PROHIBITED

ALLOWED*

Subject to EDD on a case-by-case basis

United States of America

ALLOWED

ALLOWED*

Subject to EDD on a case-by-case basis for clients with US citizenship/residency

Venezuela

PROHIBITED

PROHIBITED


Yemen

PROHIBITED

PROHIBITED


The list above is subject to regular change / update.

Important:
Being a part of the global financial system, SPOYNT Ltd Limited relies on external financial/payment partners for performing certain operations (including transfers and accounts). It is SPOYNT Ltd’s obligation to adhere to partners’ policies and terms of business, thus, SPOYNT Ltd reserves the right to refuse its Clients certain actions and prohibit transactions as required by its partners terms and conditions.
Appendix B – Prohibited Business/ Transactions
SPOYNT Ltd will not provide account or payment services to entities operating in or related to the following sectors/industries:

Type of Business

Reason

Anonymous or Numbered Accounts, unincorporated or unregistered entities, Shell Banking (i.e., banks incorporated in a jurisdiction without a physical presence and unaffiliated with a regulated financial group)

Restricted / High-risk

Cash and Check Handling: Check Cashing, Deposit Taking, Cash Transfer

Restricted / High-risk

Credit repair, Debt Restructuring, Debt Recovery, Debt Settlement, Debt Collections

Restricted / High-risk

Embassies, Consulates, and other Governmental Bodies

Restricted / High-risk

Tobacco, E-Cigarettes, and E-Liquid

Restricted / High-risk

Operating a business requiring a license or special permit without obtaining such a license (e.g., Unregulated Auction Houses)

Restricted / High-risk

Production of Adult or Violent Content

Restricted / High-risk

Production or Distribution of Offensive Weapons: Ammunition, Firearms, Explosives, Complex Weapons (e.g., guided missiles), Poisons

Restricted / High-risk

Transactions involving Human Organs

Illegal

Sanctioned Individuals and Entities

Restricted

Services of Psychic Services, Occult, Pseudo-Sciences, Alternative Medicine

Other

Financial Pyramid or Ponzi Schemes

Illegal

Any industry known to be illegal in its local jurisdiction or the UK

Illegal

Illegal Drugs and Narcotics

Illegal

Supply, Sale, and Distribution of certain Recreational Drugs (including lawful medicinal marijuana distributors)

Legal in certain jurisdictions

The sale or distribution of Stolen Goods (including digital and virtual goods), Counterfeit Goods, or Violation of Intellectual Property Rights

Illegal

Selling, Hosting, Distributing, Producing, or Promoting Offensive Materials, including those inciting racial hatred or discrimination based on gender, race, religion, national origin, physical ability, sexual orientation, or age

Illegal

Alternative / Informal / Unregulated Payment Systems (e.g., Hawala, Chit, Poey Kuan, Hundi, Fei Chi 'Ien')

High Risk / Illegal

Virtual Currency Exchanges, Administrators, or Miners and/or Cryptoasset Exchange Providers or Custodian Wallet Providers that are not licensed or regulated in an equivalent jurisdiction

Illegal

Illegal, Unregulated, Unlicensed, or Unauthorized Gambling or Gaming Firms

Illegal

Trafficking of Cultural Artefacts and/or Wildlife or Protected Species

Illegal

Offenders of Environmental Regulations and Perpetrators of Environmental Crime

Illegal

Human Trafficking, Modern Slavery, Unlicensed Migration / Employment Agencies

Illegal

Unincorporated Entities

Not allowed

Entities with Complex Ownership Structures where the UBO is separated by over three layers of ownership and control

Not allowed

Legal Entities with Complex Ownership/Management Structures that lack apparent commercial rationale and obstruct CDD disclosure and UBO identification

Prohibited

Appendix C – High-Risk-Business / Transactions
Provision of payment and account services related to the following industries and types of activities may be subject to separate EDD (Enhanced Due Diligence) / KYB (Know Your Business) / KYCC (Know Your Customer’s Customer) / Risk Analysis and Banking Provider’s Approval.

Type of Business

Risk Level

Licensed Cryptocurrency Exchanges, Platforms, and Crypto Payments

High Risk / High Volatility

High-Value Dealers (Jewelry, Art, Auctions, Automotive)

High Risk

Crowdfunding / Crowd Investing Platforms

High Risk

Second-Hand Vehicle Sales

High Risk

Extractive Industries (Mining, Crude Oil/Gas)

High Risk

Cash-Intensive Businesses (Cash-and-Carry, Scrap Metal, Beauty Industry)

High Risk

Professional Sports

High Risk

Payroll Operators, Licensed HR Consultants

High Risk

Tour Operators

High Risk

Charities, Non-Profit Organizations, Foundations, and Cultural Associations (including donation-based entities)

High Risk

Professional Providers of Corporate Services, Tax Advisory, Citizenship by Investment, Legal Advisory

High Risk

Legal Entities using Nominee Directors / Secretaries / Shareholders

High Risk

Penny Stocks or Microcap Securities

High Risk

Payments involving General Trading Companies operating in Free Trade Zones (FTZ)

High Risk

Regulated Payment Service Providers / Money Service Businesses (MSBs)

Regulated / High Risk

Payments involving Downstream Processing for Correspondent Banks, MSBs, Financial Institutions, and Payment Service Providers that are not otherwise prohibited

Regulated / High Risk