Risk Appetite Policy

1. Purpose

This Risk Appetite Policy describes categories of businesses, activities, relationships, and jurisdictions that Apex Advisory Group Ltd (“CyberPay”) prohibits or restricts. It helps Merchants assess eligibility and informs Buyer protections and partner expectations. This is a public summary. CyberPay may apply additional internal criteria, partner requirements, and transaction-level controls, and may refuse/suspend/terminate at its sole discretion.

2. Strictly Prohibited Businesses and Activities (Non-Exhaustive)

CyberPay will not support, directly or indirectly:

• sanctions evasion; money laundering; terrorist financing
• child exploitation (zero tolerance), trafficking, or related content/services
• illegal drugs, controlled substances sold unlawfully, or related paraphernalia
• weapons, ammunition, weapon parts, or related equipment
• counterfeit goods, piracy, IP infringement, or circumvention services
• malware, phishing, credential theft, stolen data, cybercrime facilitation
• fraud schemes: Ponzi/pyramid/matrix schemes, “get rich quick”, investment scams
• bribery, corruption, facilitation payments, kickbacks
• illegal gambling / unlicensed gambling services
• illegal wildlife trade or trafficking in protected species
• unregulated financial operations (unlicensed MSBs, exchanges, value transfer)
• deceptive marketing, affiliate manipulation, click farms, traffic laundering
• shell banks, anonymous relationships, or opaque structures with insufficient BO transparency CyberPay may refuse additional categories based on partner rules or risk assessment.
• adult content, pornography, escort or adult-dating services
• unlicensed or high-risk forex, CFD, binary options, or margin/leveraged-trading services
• nutraceuticals, supplements, or wellness products making unsubstantiated or misleading health claims
• CBD, cannabis, hemp-derived, or related products and paraphernalia
• gambling, betting, lotteries, or games of chance without valid licensing in every relevant jurisdiction

3. Restricted / High-Risk Categories (Enhanced Review Required)

• CyberPay may support only with enhanced review/controls (KYB/EDD, limits, reserves/holds, monitoring, partner acceptance):
• adult content and dating services (lawful only, age controls required)
• regulated gambling (licensed only; partner acceptance required)
• future-delivery merchants (travel, tickets, events; delivery risk)
• gaming/virtual goods (fraud and dispute risk overlays)
• financial service providers (regulated only; heavy due diligence)
• crowdfunding and regulated fundraising
• forex trading (regulated only)
• telecom/VOIP/airtime (compliance required)
• virtual asset services (licensed/registered only; high scrutiny)

4. Prohibited Business Relationships

• CyberPay will not engage with:
• shell banks
• sanctioned entities/persons
• anonymous accounts
• bearer share structures (where applicable)
• relationships lacking sufficient transparency on beneficial ownership/control

5. Jurisdictions

• CyberPay does not support sanctioned jurisdictions and restricts high-risk jurisdictions consistent with international standards (including FATF high-risk lists) and partner requirements.

6. Violations and Reporting

• If you believe your activity may fall into prohibited/restricted categories, contact Compliance before transacting. CyberPay may suspend/terminate for actual or suspected violations.