Legal

‍Introduction and Scope

Grey provides foreign virtual accounts and cross-border payment services to eligible business customers (“Business Customers”, “you”, “your”) to enable the receipt and making of payments, subject to applicable eligibility requirements (the “Services”).

Eligibility to use Grey’s Services may depend on your business activities, industry sector, country of incorporation, jurisdiction of operation, customer base, transaction patterns, applicable anti-money laundering/counter-terrorist financing (“AML/CFT”) laws, Grey’s internal risk management policies, and such other criteria as Grey may determine from time to time at its sole discretion.

This Acceptable Use Policy (the “Policy”) sets out the permitted and prohibited uses of Grey’s platform (the “Platform”) and Services and applies to all Business Customers, directors, officers, shareholders, employees, contractors, agents, and any authorised users acting under your Grey account.

By accessing or using our Services, you agree to comply with this Policy and all applicable laws and regulations. If you do not agree, you must immediately discontinue use of our Services, as continued use constitutes acceptance of this Policy and all related policies.

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Business Verification and Eligibility Requirements

Grey is committed to preventing fraud, money laundering, terrorist financing, sanctions breaches, and other illicit activities. Accordingly, Grey does not support businesses with unclear, unverifiable, or ambiguous sources of funds, business models, or transaction purposes.

You are required to provide Grey with complete, accurate, and up-to-date information and documentation relating to your business, including but not limited to:

1. certificate of incorporation/registration documents;

2. tax identification number and business address;

3. details of directors, shareholders and beneficial owners;

4. nature of business operations and source of funds;

5. expected transaction volumes and payment flows;

6. customer profile (where applicable);

7. contracts, invoices, or evidence of business activity;

8. such other documentation Grey may reasonably request.

Grey reserves the right to reject your application or suspend onboarding where Grey is not satisfied that your proposed use of the Platform is legitimate and compliant.

Grey will only approve or maintain your access where, upon review of your submitted information, Grey is satisfied that your business operations and intended transactions are consistent with the use of a foreign virtual account and Grey’s compliance requirements.

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Permitted Uses of Grey’s Platform

Subject to compliance with this Policy and applicable law, Grey’s Platform may be used for legitimate business-related purposes including:

1. receiving payments from customers, clients, business partners, and third parties for goods and services;

2. receiving proceeds of trade, consulting services, professional services, and export-related income;

3. receiving payouts from e-commerce platforms, freelance platforms, and marketplaces where such activity is conducted as part of your business;

4. paying suppliers, vendors, contractors, service providers and business partners;

5. receiving business revenue and making operational payments including payroll and overheads (where permitted by Grey);

6. receiving investment proceeds or capital inflows where such inflows are lawful and verifiable, and where Grey has approved such use.

Grey may require additional review or approvals depending on the nature of your industry, transaction profile, or jurisdiction of operations.

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Corporate Account Responsibility and Authorised Users

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Use of Account by the Business

All activities conducted through your Grey account shall be deemed to have been carried out by you as the registered Business Customer.

You are responsible for ensuring that all authorised personnel who have access to your Grey account comply with this Policy and all applicable laws.

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Authorised Users and Access Controls

You may only permit your directors, employees, and duly authorised representatives to access and use the Grey Platform on your behalf.

You shall ensure that:

1. login credentials are not shared outside your organisation;

2. access rights are limited to authorised persons only;

3. appropriate internal approval processes exist for payments and account operations.

Grey shall not be responsible for any loss arising from misuse of your account, internal fraud, credential compromise, or unauthorised access.

If you suspect any unauthorised access or fraudulent activity, you shall notify Grey immediately for restriction, investigation or suspension of the account.

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No Use for Third-Party Payment Processing

You shall not use Grey’s Services to:

1. process payments on behalf of third parties;

2. act as a payment intermediary, payment aggregator, escrow agent, or collection agent;

3. receive funds for the benefit of another unrelated person or business;

4. provide “wallet” or “banking” services to third parties.

Grey may approve certain payment facilitation models (e.g., marketplaces, platforms, licensed payment entities, SaaS subscription models) on a case-by-case basis, subject to enhanced due diligence and Grey’s written approval.

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One Account Per Business Entity

You may only open and operate one Grey account per legal business entity unless Grey has expressly agreed in writing to the opening of additional accounts.

Where duplicate accounts are detected, Grey reserves the right to suspend, close, consolidate, or merge such accounts at its sole discretion.

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Restricted Activities (General Prohibited Use)

You may use Grey’s Platform only for lawful business purposes. You may not use the Platform:

1. in any way that breaches any applicable local, national or international law or regulation, or causes Grey to breach any law or regulation;

2. for any unlawful, fraudulent, deceptive, dishonest or misleading activity;

3. for the purpose of concealing or disguising the origin, ownership or destination of funds;

4. to facilitate money laundering, terrorist financing, tax evasion or sanctions circumvention;

5. to provide services or receive funds connected with bribery, corruption, or political exposure risks without disclosure and approval;

6. for any unsolicited advertising, promotional material or spam;

7. to distribute malware, viruses, spyware or other harmful code;

8. in a manner likely to result in disputes, reversals, chargebacks, complaints, penalties or liabilities to Grey, other customers, or third parties;

9. in a manner inconsistent with the stated purpose of your business or declared transaction profile.

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Prohibited Transactions and Restricted Lines of Business

Grey does not support transactions relating to the following restricted lines of business (“Restricted Businesses”), whether directly or indirectly, including but not limited to:

1. Any criminal or illegal activity in breach of applicable laws or regulations including:

1. illegal narcotics;

2. child sexual exploitation material;

3. human trafficking;

4. terrorist financing;

5. stolen goods or stolen funds;

6. illegal wildlife trade;

7. smuggling and unlawful import/export activity.

2. Any gambling, sports betting, lotteries, gaming operations, or related payment processing.

3. Any currency exchange, money transmission or money services business, including:

1. foreign exchange trading (FX dealing);

2. remittance operations;

3. bureau de change services;

4. cryptocurrency exchange services;

5. stablecoin exchange or brokerage;

6. virtual asset service provider activity (unless expressly approved).

4. Any investment schemes, Ponzi schemes, pyramid schemes, “get rich quick” programmes, or businesses that offer unrealistic financial returns.

5. Any business involving counterfeit goods, copyright infringement, piracy, trademark infringement, or sale of imitation products.

6. Unauthorised reselling of event tickets or scalping.

7. Sale or distribution of firearms, firearm parts or accessories, ammunition, explosives, or knives/weapons.

8. Adult entertainment, pornography, escort services, prostitution, or adult content websites.

9. Sale, distribution or promotion of prescription drugs, controlled substances, and pharmaceutical products unless licensed and approved.

10. Unlicensed financial services including:

1. dealing in stocks, securities, derivatives or commodities;

2. investment advisory services without proper authorisation;

3. lending/loan sharking activity;

4. unlicensed insurance services.

11. Any product or service that promotes hate, violence, racial intolerance, extremism, or discrimination.

12. Any product or service that is illegal, or marketed or sold in a way that may create regulatory liability for Grey.

High-Risk Business Models

Certain industries may be allowed only subject to Grey’s prior written approval, enhanced due diligence, and transaction monitoring. These may include:

1. marketplace platforms;

2. digital asset businesses with clear licensing;

3. fintech infrastructure providers;

4. cross-border logistics/export businesses;

5. businesses operating in high-risk jurisdictions;

6. charities and NGOs;

7. politically exposed industries.

Grey reserves the right to request additional documentation, impose limits, or decline such businesses entirely at its sole discretion.

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Monitoring, Enforcement and Suspension Rights

Grey may monitor account activity and transaction behaviour to ensure compliance with this Policy, applicable law, and regulatory obligations.

Where Grey determines (in its sole discretion) that you have breached this Policy or present a compliance risk, Grey may:

1. suspend or restrict your account;

2. freeze funds pending investigation or regulatory reporting;

3. decline, reverse or cancel transactions;

4. request additional documentation or explanations;

5. terminate your account relationship without liability;

6. report suspicious activity to relevant authorities where required by law.

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‍Reporting and Cooperation Obligations

You agree to promptly provide Grey with any information or documents required to:

1. verify the legitimacy of transactions;

2. confirm the source of funds and nature of payments;

3. support Grey’s regulatory and compliance obligations.

Failure to cooperate with Grey’s compliance requests may result in suspension or termination of services.

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Disclaimer

We are under no obligation to monitor your use of the Services for your benefit or for the benefit of any third party, and we disclaim any responsibility for any misuse of the Services by you or any authorised user on your account.

Without prejudice to the foregoing, we reserve the right (but do not undertake any obligation) to monitor, review, screen, investigate, restrict or block transactions, accounts, communications, data, content, or other materials submitted, transmitted or made available through the Services, in order to comply with applicable laws, regulatory obligations, internal risk management policies, or lawful requests from competent authorities.

We shall not be responsible for any content, information, instructions, payment details, transaction references, documentation, communications, or other materials created, provided, stored, transmitted, or made accessible by you or any third party through the Services, and we are not obliged to exercise any editorial control over such materials.

If we become aware that any such activity, content or material violates this Policy, we may (without liability) remove such material, suspend or terminate your access to the Services, block your account, freeze or restrict transactions, and/or report such breach or suspicious activity to law enforcement agencies or relevant regulatory authorities, where required by law or where we deem appropriate.

Unless otherwise expressly stated in this Policy or in an agreement executed between you and the Company, we disclaim any duty or obligation to any person who has not entered into a contractual relationship with the Company for the use of the Services.

To the fullest extent permitted by applicable law, we exclude liability for any loss, damage, claim, penalty or expense arising from or connected with your breach of this Policy or the actions or omissions of your employees, agents, contractors or authorised users.

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Updates and Modifications to this Policy

Grey reserves the right to update, modify, or revise this Policy at any time to reflect changes in legal requirements, business operations, or Platform functionality. Any updates to this Policy will be effective upon posting on the Platform or as otherwise communicated to users.

Where required by law, we will notify users of significant changes. Continued use of the Services after any modifications constitutes acceptance of the revised Policy. 

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Contact

If you have any questions, concerns, or reports regarding this Acceptable Use Policy, you may contact us through:

Support Email: business@grey.co