Specific examples of clients that are outside of Arival’s risk tolerance include, but are not limited to:

  1. Persons appearing in the information available from which it may be deducted that they might be connected to criminal activities, particularly those supposedly connected to drug dealing or trafficking, terrorism, and organized crime;

  2. Clients convicted of a federal crime involving securities, commodities, financial services, fraud, or theft;

  3. Entities whose primary line of business is illegal in the jurisdiction where it is conducted, or in the jurisdiction in which Arival is registered to do business;

  4. Entities operating from/within OFAC sanctioned countries, when sanctions are imposed on the entire country and not with respect to specific individuals and/or entities;

  5. Persons whose business is such that it makes it impossible to verify the legitimacy of the activities involved, or the source of funds;

  6. Anonymous accounts, nominee accounts, or accounts in fictitious names;

  7. Individuals reluctant to facilitate the information or documents requested;

  8. Shell companies, without real economic activity in the jurisdiction of registration;

  9. Clients engaged in the following categories of business activities:

  • Gaming & gambling services;

  • Pseudo-pharmaceuticals;

  • Weapons vendors/ sale and manufacturers;

  • Illegal / controlled substance vendors;

  • Drugs / Drugs Paraphernalia;

  • Illegal activities;

  • Adult Content/ Services;

  • Multi-Level Marketing (MLM);

  • Illegal products and services;

  • Counterfeit or unauthorized goods.

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