| Illegal drugs & drug paraphernalia |
Narcotics, psychotropic substances, and equipment used to make or take them — unless part of a properly licensed pharmaceutical or medical supply chain. |
| Weapons, arms & military equipment |
Making, selling, brokering or trading arms, ammunition, explosives or military/paramilitary equipment. This is a no-go regardless of any licence held. |
| Child sexual abuse material & exploitation of minors |
Any content, service or platform that sexualises, exploits, or facilitates the abuse or trafficking of children. |
| Human trafficking, forced labour & commercial sexual exploitation |
Any business connected to trafficking people or forcing them to work. |
| Escort services |
Escort agencies and related booking or facilitation services — even if marketed as separate from prostitution or sexual exploitation. |
| Terrorism & proliferation financing |
Any entity or activity that supports a designated terrorist organisation, or that helps finance weapons of mass destruction. |
| Sanctioned countries, entities & individuals |
Any party or activity subject to UN, OFAC, EU, UK or local sanctions. |
| Unlicensed gambling, betting & lottery |
Betting, casino, lottery or gaming operations that don't hold a valid gambling licence for the market they operate in. |
| Pyramid schemes & unregistered investment schemes |
Schemes that mainly pay returns from new investors' money rather than real underlying business activity, and investment schemes that aren't properly registered. |
| Unlicensed deposit-taking, lending or money transfer |
Taking deposits, lending money or transmitting funds without the licence that activity requires in that market. |
| Counterfeit goods, piracy & IP infringement |
Selling fake or pirated products, or content/software that infringes someone else's intellectual property. |
| Stolen goods & illegally obtained property |
Trading in goods known or reasonably suspected to be stolen or otherwise unlawfully obtained. |
| Illegal wildlife trade & environmental crime |
Trading endangered species or products (CITES-listed), illegal logging, illegal mining, or unlawful dumping of waste. |
| Malware, hacking tools & unlawful surveillance |
Selling hacking services, malware, spyware, or tools built to access systems or data without permission. |
| Fraud, deception & scams |
Fake documents, fake academic credentials, get-rich-quick scams, and similar deceptive operations. |
| Trade in human body parts, organs or remains |
Any commercial dealing in human organs, tissue or remains, outside lawful medical or scientific use. |
| Adult content & adult entertainment |
Pornography, adult entertainment platforms, and any sexual content or services — full stop. No licence, age-verification system or classification changes this. This also rules out non-consensual content or content that's illegal wherever it's made, hosted or sold. |
| Hate speech & incitement to violence |
Platforms or merchants whose main purpose is promoting hatred, discrimination or violence against a protected group. |
| Online pharmacies |
Selling or dispensing medicines — prescription or not — through an internet-based pharmacy. This applies even with a licence. |
| Shell companies |
Companies with no real business activity, no economic substance, or unclear ownership, used mainly to hold or move money. |
| Unregistered charities |
Charitable, religious or non-profit fundraising by an entity that isn't registered with the relevant charity regulator in its market. |
| Telemarketing |
Outbound telemarketing and cold-call-based sales. |
| Regulated businesses without proper compliance controls |
Operating in a regulated sector without the required licence, or without adequate compliance controls in place. |
| Anything else that poses a material risk to us |
Any other activity that, in our reasonable assessment, poses material reputational or brand risk to PawaPay — assessed case by case, even if not listed above. |
