Last modified on October, 31st. 2023.
ACCEPTANCE POLICY
HiPay SAS
VERSION 10 (10/2023)
94, rue de Villiers - 92300 Levallois-Perret
S.A.S au capital de 11 125 143.00€ - RCS Nanterre B 390 334 225
Summary of Changes
OWNER OF THE MACRO-PROCESS
Name
First name
Fonction
Pirau
d
Matthieu
Chief Risk Compliance and Permanent Control Officer
OWNER OF THE PROCESS
Name
First
name
Fonction
Piraud
Matthieu
Chief Risk Compliance and Permanent Control Officer
WRITING
By
Date
By
Date
Lara Baguet
05/2022
Geneviève Guintran/Grégoire Bourdin
13/05/2022
VALIDATION
Owner of the Macro-process
(OM)
Risk Committee
OM’s Name
Date
Members’ Names
Date
Matthieu
Piraud
13/05/2022
Stéphanie Le Beuze; Yvan
Lefranc-Morin; Grégoire Bourdin;
Geneviève Guintran; David Cohen ;
Jérôme Daguet ; Thomas Nansot ;
Matthieu Piraud; Sarah Smirnow;
Julien Soudée.
24/06/2022
VERSIONNING
Ve
rsi
on
Date
Commentary
01
24/06/2022
Creation of the policy for both perimeters of HiPay SAS
02
31/08/2022
Approval of new EMIs
03
22/09/2022
Adding Switzerland to the appendix 3 - Merchant registration
countries
04
18/10/2022
Approval of new EMIs
05
27/01/2023
Approval of new EMIs
06
07/03/2023
Approval of new EMIs
07
25/04/2023
Approval of new EMIs Approval Andorra as registration country
08
27/06/2023
Approval of new EMIs
09
05/07/2023
Approval of new PI / News activities lists / Countries Lists Update
10
31/10/2023
Approval of new PI/EMIs
Document destination
RECIPIENTS
Confidential =
Owner Team only)
(Yes/No)
Internal = Listed HiPay
Teams only
(Yes/No)
Recipient Teams
No
No
All HiPay
External
Summary
Introduction 5
Definitions 5
Illegal lines of business 5
Refused lines of business 6
Lines of business subject to authorization 6
Merchant registration countries 6
Countries in which the merchant can neither carry out his activity nor domicile his outpayment
account 7
Outpayments to an Electronic money institution or a Payment institution account 7
Appendix 1 9
Appendix 2 10
Appendix 3 11
Appendix 4 13
Appendix 5 14
Appendix 6 15
Introduction
The purpose of this policy is to establish the requirements of HiPay SAS when entering into a
business relationship with a prospect or during the course of a business relationship with a
customer in order to offer a quality service while guaranteeing risk prevention, compliance with the
rules established by the card networks, compliance with the regulations in force and the HiPay Risk
Policy.
HiPay is responsible for setting up and monitoring knowledge of its customers with regard to its own
risk policy, its AML Policy and the regulations in force.
Since the risks vary according to the economic model of the merchant (whether prospect or
customer), HiPay carries out a risk analysis considering the specificity of each merchant.
This policy aims to categorise the conditions to enter into a relationship with a merchant as well as
the continuation of the business relationship in the event of a change in the merchant's situation.
These guidelines apply to all of HiPay SAS.
HiPay reserves the right to modify these conditions at any time.
Definitions
«Merchant» refers to prospect or customer of HiPay.
« Prospect » refers to the merchants with which HiPay plans to enter into a relationship with.
«Customer» refers to merchants which are already in a relationship with HiPay.
«End user» refers to the merchant’s customer.
Illegal lines of business
HiPay does not accept merchants whose line of business is illegal under applicable domestic law of
the country in which:
● The merchant is registered; or
● The merchant is actively marketing its products/services; or
● HiPay is registered.
Depending on the applicable law, the merchant's activity may be considered legal or illegal. It is
therefore necessary to seek the advice of the legal department in order to determine the legality of
an activity in the country concerned and the conditions attached to it.
Refused lines of business
Some lines of business, although legal, can carry a risk level too high regarding HiPay’s Risks and
AML-CTF Policies.
HiPay refuses any merchant whose line of business is on this list.
This list is available in appendix 1.
HiPay reserves the right to modify this list at any time.
Regardless of the line of business, recurring payments are refused on the Professional platform.
Lines of business subject to authorization
The prior authorisation request applies to merchants operating in good faith in certain business
sectors considered high risk ( AML-CTF or Fraud Risks ) according to HiPay's risk classification.
For this category of merchants, additional requirements and guarantees may be requested
HiPay may accept these merchants under some conditions. All lines of business listed under the
subject to authorization category require approval from the HiPay Client acceptance Committee.
The lists of these lines of business are available in appendix 2 ( AML-CTF risk ) and appendix 6
( Fraud risk ).
Some of these activities are refused on the Professional platform. These activities are identified in
appendix 2 by an *.
These lines of business include high risk merchants per payment schemes.
Merchant registration countries
HiPay is only allowed to open business relationships with merchants registered in a country in which
Hipay holds EU passporting enabled by its licence, under the freedom to provide services or any
other specific licence.
This list is available in appendix 3.
The list of HiPay’s passports is also available on the REGAFI website:
https://www.regafi.fr/spip.php?rubrique1 .
Countries in which the merchant can neither carry out his
activity nor domicile his outpayment account
Due to international sanctions and embargoes, business relations with certain countries are
restricted.
As a result, transactions to or from these countries may be prohibited.
In addition, HiPay reserves the right to prohibit transactions to or from certain countries according to
a risk based approach associated to these transactions pertaining to HiPay's Risk Policy and
AML/CFT Policy.
Countries in which the merchant can neither carry out his activity nor domicile his outpayment
account.
This list is available in appendix 4.
The following consequences result from these restrictions:
- The merchants cannot target countries included in this list;
- The country of the settlement’s bank account cannot be included in this list.
Outpayments to an Electronic money institution or a
Payment institution account
Electronic money institutions (EMIs) and payment institutions (PIs) present additional risks
compared to credit institutions.
The Compliance team is responsible for analysing any new EMI/PI, which has to be submitted to the
Client Acceptance Committee for approval.
The list of approved EMIs/PIs is available in appendix 5.
Appendix 1
Refused lines of business
Refused activities
Validation : 07/2023
Adult content websites (including nudity or any direct reference to sexual encounters)
Any service providing secondary support of illegal acvies
Beauty pageants/contests involving children
Business investment opportunies operang as get rich quick schemes (including those based on
hierarchical/pyramids, mul-level markeng, Ponzi schemes, chain leers requiring donaons, gi
giving that encourages one to recruit people into a club in order to receive a return on investment)
Cash advances, cheque cashing
Claims Management Services (e.g. PPI, PBA, SERPS compensaons)
Cryptocurrencies – anonymous (digital or virtual currency that uses cryptography for security including
but not limited to bitcoin)
Escort services
Filesharing & online storing (due to risk of infringement on copyrights)
Gold & precious materials & precious stones
Merchants, principals or related enes previously idenfied by regulators or card scheme for
decepve pracces or any violaon of standards
Money transfer services or Money Service Businesses (money transmiers, wire transfers,
issiung/selling/redeeming of money orders or travelers cheques, cash advances, cheque cashing,
online vouchers)
Pay day lenders and/or pay day loan facilitator
Penny aucons
Pharmaceucal (prescripon drugs) – sale of non-face-to-face
Polical acvies
Prepaid cards (anonymous)
Private local network currencies e.g. Monnaie Locale Complémentaire (MLC). Some examples include
Coopek, Sol- Violee, Eusko etc.
Religious acvies
Sale of certain types of drugs or chemicals (such as synthec drugs; salvia divinorum, psilocybin
mushrooms and spores, and nitrite inhalants)
Sale of weapons (for personal or commercial use even if licensed)
Trade in animals (live or dead) and animal products of any nature (per internaonal trade guidelines)
Appendix 2
Lines of business subject to authorization
Activities with an * are refused for Professional
High risk industries
Validation : 07/2023
Industry
Administrave assistance (of all kinds)
Adversing inserts
agribusiness
aircra industry
Any business model including cash back, “free gi/ prize”, guaranteed rebate, refund, sweepstakes as an
inducement to purchase a product/service
Arms industry*
associave and humanitarian sector
Automove sector (except res)
Binary opon brokers/dealers
construcon industry
Corporate consulng
Crowdfunding/crowdlending services*
Cryptoassets (non anonymous)*
Digital Markeng
Energy industry*
Extracve industry*
Financial services (including new alternave payments methods, online banking e.g. neobanks)
Foreign exchange, forex (including buying, selling and exchanging of currencies)*
Fortune telling
Gambling*
Gaming and digital goods
Gi Cards*
healthcare (including pharmacies and drug stores) and research instuons
Insurance agents/brokers
Internet dang sites
IT consulng and tech support
Luxury Jewellery
Military equipment*
Industry
Mobile phone company/pre-owned mobile phone retailer
Nutraceucals (dietary supplements) : Product must not include any ingredient or substance that are:
- regulated or require a license or prescripon;
- illegal or prohibited by law or the schemes such as synthec drugs, salvia divinorum, psilocybin
mushrooms and spores, and nitrite inhalants.
Merchants are required to list ingredients.
Para-pharmacies (nonprescripon products only).Product must not include ingredients that are regulated or
require a license or prescripon.
Pay TV subscripons
Private auconing*
Public auconing*
public body
Real estate*
scienfic acvies
Self-employed worker
Shipping industry
Tobacco products (excluding e-cigarees and smokeless cigarees)*
VPN Access, Web hosng services and Computer Network/Informaon Services
Appendix 3
Merchant registration countries
Pays d'immatriculation du marchand
Date de publication : 04/2023
ISO
Pays
Area
AD
Andorre (e-commerce)
Other
AT
Austria
EU
BE
Belgium
EU
BG
Bulgaria
EU
HR
Croatia
EU
CY
Cyprus
EU
CZ
Czech Republic
EU
DK
Denmark
EU
EE
Estonia
EU
FI
Finland
EU
FR
France
EU
ISO
Pays
Area
DE
Germany
EU
GR
Greece
EU
HU
Hungary
EU
IE
Ireland
EU
IT
Italy
EU
LV
Latvia
EU
LT
Lithuania
EU
LU
Luxembourg
EU
MT
Malta
EU
NL
Netherlands
EU
PL
Poland
EU
PT
Portugal
EU
RO
Romania
EU
SK
Slovakia
EU
SI
Slovenia
EU
ES
Spain
EU
SE
Sweden
EU
CH
Switzerland (e-commerce)
other
UK
United Kingdom (e-commerce)
other
IS
Iceland
EEA
LI
Liechtenstein
EEA
NO
Norway
EEA
Appendix 4
Refused transactions
Refused transacons countries
GAFI + embargos/sancons + fraud fighng
Validaon : 07/2023
Iso
Country
AF
Afghanistan
AL
Albanie
BB
Barbados
KH
Cambodia
CF
Central African Republic
CG
Congo (Brazzaville)
CU
Cuba
GQ
Equatorial Guinea
ER
Eritrea
ET
Ethiopia
GH
Ghana
GN
Guinea
GW
Guinea-Bissau
HT
Hai
IR
Iran
IQ
Iraq
JM
Jamaica
LR
Liberia
LY
Libya
MM
Myanmar (Burma)
NA
Namibia
NI
Nicaragua
KP
North Korea
PK
Pakistan
PA
Panama
SO
Somalia
LK
SriLanka
SD
Sudan
SY
Syria
TJ
Tajikistan
TT
Trinidad & Tobago
UG
Uganda
YE
Yemen
Appendix 5
Approved EMIs Pis
Name
Country of registration
Approval
Aion Bank
Belgium
31/12/2021
Airwallex
Netherlands
29/8/2023
ANNA Money
UK
1/8/2023
Anyme
Belgium
27/9/2022
Blank SAS
France
5/7/2022
Bunq
Netherlands
30/8/2022
Currenxie
UK
27/1/2023
Ebury
UK
30/8/2022
Equals group PLC
UK
19/9/2023
FINOM
Netherlands
30/8/2022
Fire Financial Services Limited
UK/Ireland
25/11/2021
iBanq (IFX Payments Limited)
UK
26/4/2022
ISX Financial EU PLC
Cyprus
26/7/2022
KNAB
Netherlands
21/3/2023
Manager.one
France
31/12/2021
Monese
UK
27/12/2019
Monzo
UK
27/12/2019
N26
Germany
27/12/2019
Paykrom
France
28/2/2023
Payoneer
UK
15/6/2021
Paysera LT
Lithuania
18/10/2022
Pennylane
France
4/7/2023
Penta
Germany
26/7/2022
Qonto
France
27/12/2019
Revolut
UK
27/12/2019
Shine
France
27/12/2019
Sogexia
Luxembourg
6/12/2022
Starling Bank
UK
20/6/2023
SumUp
Ireland
17/1/2023
SWAN
France
30/8/2022
Transferwise
UK
27/12/2019
Treezor
France
1/4/2021
Viva Wallet
Greece
27/9/2022
Worldfirst
UK
26/7/2022
Appendix 6
List of fraud risk activities
Fraud risk activities
Validation : 07/2023
Activities
Car accessories (res, spare parts, ...)
Digital goods and services
Drugstore and cosmecs
Fortune telling
Fuel cards (ex : Total)
Gi cards
High Tech products (Mobiles, digital pads, computers, ...)
Hotels, resorts and vacaon rental (tourists accommodaons)
iGaming, online gaming
Luxury jewellery (watches, gemstones etc.)
Meal delivery
Online gambling (poker, sports bets, ...)
Sell of sports goods
Sell of well-known brands products
Tickeng: Purchase of ckets for events (concerts, fesvals etc.), leisure parks, exhibions,....
Tourist coaches
Travel agencies and tour operator
Vehicules rental (car, motorbike, scooter, boat, ...)