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	ALLOWED*	ALLOWED*	Subject to EDD on a case-by-case basis
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	ALLOWED*	ALLOWED*	Subject to EDD on a case-by-case basis
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	ALLOWED*	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