1. Purpose

This Prohibited Activities Policy (“Policy”) describes activities, merchant categories, and transaction behaviours that are strictly restricted when using the CosmanX Platform.

By accessing or using the Platform, the User agrees to comply with all restrictions and requirements set out in this Policy.

2. General Prohibitions

The User must not use the Platform or Virtual Cards for:

• illegal, deceptive, or fraudulent activity;
• attempting to bypass compliance controls, MCC restrictions, geographic rules, or risk-monitoring systems;
• impersonating another person or entity, or providing a false or misleading business identity;
• reselling, transferring, or making Virtual Cards available to unauthorized third parties; or
• processing or facilitating payments on behalf of businesses or individuals that have not been properly verified.

3. Prohibited Merchant Categories

Users must not use CosmanX Virtual Cards for transactions involving any of the following categories:

• gambling, casinos, betting services, or lotteries;
• adult entertainment, escort services, or pornographic content;
• cryptocurrency exchanges, token launches, mining services, or DeFi protocols;
• unlicensed financial services, foreign exchange, remittance services, or investment schemes;
• IPTV, piracy-related services, or streaming tools that infringe copyright;
• pharmaceuticals, steroids, medical products, or CBD products requiring regulatory certification;
• high-risk nutraceuticals or health supplements lacking required FDA, CE, or equivalent certification;
• hacking tools, malware, spoofing services, cloaking tools, or identity-manipulation services;
• firearms, ammunition, or tactical products restricted by applicable law;
• replica goods, counterfeit merchandise, or fake branded products;
• political fundraising or unregulated charitable activity; and
• any merchant category prohibited by Visa, Mastercard, acquiring banks, Partner Issuers, or other applicable payment partners.

This list is not exhaustive and may be revised as compliance, partner, legal, or risk requirements change.

4. Geographic Restrictions

Users must not access, fund, or use Virtual Cards:

• from jurisdictions subject to applicable OFAC sanctions;
• from countries classified by FATF as high risk;
• from non-cooperative jurisdictions or locations that do not support adequate KYC standards.

Additional geographic restrictions may be defined in the applicable Terms, partner requirements, or other CosmanX policies.

Attempts to bypass geographic restrictions through VPNs, sub-accounts, intermediaries, nominees, or other indirect access methods are also prohibited.

5. Transaction Pattern Restrictions

The following transaction patterns are prohibited and may result in immediate review, restriction, or suspension:

• excessive failed transactions or unusual transaction-velocity spikes;
• spending patterns that materially differ from the business purpose provided during onboarding or review;
• abnormal or unexplained changes in MCC activity over a short period;
• attempts to run high-risk advertising activity after prior platform or account suspensions; and
• structured or coordinated attempts to evade automated monitoring or compliance controls.

6. Funding Restrictions

Users must not:

• fund an Account using stolen, tested, compromised, or otherwise unauthorized payment cards;
• attempt funding methods designed to create or exploit chargebacks; or
• make digital-asset deposits originating from mixers, tumblers, sanctioned wallets, or high-risk exchanges.

7. Sub-account / Team Restrictions

The primary Account owner is responsible for ensuring that employees, Team members, sub-account users, and other authorized Users do not:

• spend outside approved or permitted business categories;
• attempt transactions involving restricted MCCs;
• operate or access the Services from prohibited jurisdictions; or
• breach applicable compliance, verification, or risk requirements.

Violations committed by a Team member may be treated as violations affecting the entire Account.

8. Enforcement and Penalties

Where CosmanX identifies prohibited activity, the Company may, subject to applicable law, partner requirements, and contractual terms:

• suspend or terminate an Account or Virtual Cards, including without advance notice where appropriate;
• permanently restrict access to some or all Services;
• request additional documents, verification, or supporting information before considering reinstatement; and
• decline dispute, reimbursement, or compensation requests relating to prohibited activity where permitted.

Refunds may not be available where enforcement action results directly from prohibited or non-compliant activity, subject to applicable law and the terms of the relevant partner program.

9. Amendments

CosmanX may update this Policy from time to time to reflect changes in law, regulation, card-network rules, partner requirements, or internal risk controls.

Unless otherwise stated, revised restrictions become effective when published on the Platform. Continued use of the Platform following publication constitutes acknowledgement of the updated Policy.

10. Contact

For questions relating to this Prohibited Activities Policy, please contact: