Acceptable Use Policy

1. Purpose and Principles

The integrity of the payments ecosystem depends on responsible participation by all parties involved in the movement of funds and payment data.

As a payment orchestration platform, OKARDS is committed to supporting a secure, lawful, and trustworthy environment for merchants, acquiring partners, payment service providers, and other participants in the payment chain.

This Acceptable Use Policy establishes the principles governing access to and use of the OKARDS platform. The Policy is designed to protect the integrity of our services, support the compliance obligations of our partners, and mitigate legal, sanctions, fraud, security, and reputational risks associated with payment processing activities.

OKARDS provides technology that enables payment routing and orchestration. We do not act as an acquiring bank, settlement institution, or regulated payment processor. Accordingly, this Policy is focused on determining whether a business is appropriate for access to the OKARDS platform and does not replace the underwriting, monitoring, or risk management processes performed by acquiring banks or payment service providers.

2. Risk-Based Access to the Platform

Access to the OKARDS platform is based on a risk-based assessment of each prospective and existing counterparty.

In evaluating whether a business is appropriate for the platform, OKARDS may consider a range of factors, including:

• the nature of the business and products offered;
• applicable legal and regulatory requirements;
• sanctions exposure;
• reputational considerations;
• transparency of ownership and control;
• compliance history;
• requirements imposed by acquiring partners, payment service providers, or card schemes.

The fact that a business operates lawfully does not automatically guarantee eligibility for access to the platform. Certain activities may present risks that are incompatible with the services provided by OKARDS or the requirements of our partners.

OKARDS reserves the right to approve, restrict, suspend, or terminate access where it reasonably determines that a business presents unacceptable risk.

3. Activities Incompatible with the Platform

OKARDS does not permit the use of its platform for any activity that is illegal, fraudulent, deceptive, sanctioned, or otherwise incompatible with the integrity of the payment ecosystem.

This includes, but is not limited to, activities that:

• violate applicable laws or regulations;
• facilitate fraud, money laundering, terrorist financing, sanctions evasion, or other financial crime;
• involve sanctioned individuals, entities, or jurisdictions;
• exploit, harm, abuse, or endanger individuals;
• conceal or misrepresent the identity of beneficial owners, controlling persons, or the true nature of business activities;
• involve forged, falsified, misleading, or deceptive information or documentation;
• attempt to circumvent card scheme rules, regulatory requirements, or payment security controls;
• otherwise compromise the security, stability, or integrity of payment systems.

If, at any time during the business relationship, OKARDS becomes aware of information indicating that a counterparty is engaged in, facilitates, or is otherwise connected with any such activity, OKARDS may immediately suspend or terminate access to the platform without prior notice, refuse to process further transactions, and take any other action permitted under applicable law or the parties' agreement.

Where required or permitted by applicable law, regulatory obligations, or requests from competent authorities, OKARDS may disclose relevant information and cooperate with regulators, law enforcement agencies, card schemes, financial institutions, or other competent authorities as appropriate.

4. Higher-Risk Business Activities

Certain business sectors may require enhanced review before access to the platform is granted.

Examples may include businesses operating in areas such as gambling, digital assets, financial services, marketplaces, subscription-based services, adult content, or other sectors presenting elevated legal, regulatory, fraud, or reputational risk.

Enhanced review does not imply that a business is prohibited. Rather, it reflects the need for additional information to determine whether the activity is consistent with OKARDS' risk appetite and the requirements of relevant payment partners.

Approval of higher-risk business activities remains subject to the discretion of OKARDS and, where relevant, the requirements of acquiring partners and payment service providers.

5. Transparency and Accurate Information

Trust within the payments ecosystem depends upon transparency.

Clients are expected to provide complete and accurate information regarding their business activities, ownership structure, products, services, websites, regulatory status, and acquiring relationships.

Businesses must not:

• misrepresent the nature of their activities;
• conceal ownership or control;
• use the platform for activities materially different from those disclosed during onboarding;
• attempt to circumvent compliance or risk controls.

Failure to provide accurate information may result in suspension or termination of access to the platform.

6. Ongoing Compliance Expectations

Use of the OKARDS platform is subject to ongoing compliance with this Policy.

Clients are expected to notify OKARDS of material changes to their business activities, ownership structure, regulatory status, or acquiring relationships where such changes may affect their risk profile.

OKARDS may periodically review counterparties and request information reasonably necessary to assess continued compliance with this Policy and the safe operation of the platform.

7. Protection of the Payments Ecosystem

OKARDS believes that maintaining trust in payments requires cooperation among merchants, technology providers, acquiring banks, payment service providers, and regulators.

Where appropriate, OKARDS may take reasonable steps to support the integrity, security, and lawful use of payment services, including cooperating with acquiring partners, payment service providers, and competent authorities in connection with legitimate compliance, fraud prevention, sanctions, or security matters.

These measures are intended to protect the platform, its users, and the broader payments ecosystem from misuse and abuse.

8. Enforcement and Review

OKARDS reserves the right to take any action reasonably necessary to enforce this Policy and protect the integrity of its platform.

Such actions may include requesting additional information, applying restrictions, suspending services, declining onboarding, or terminating access where activities are inconsistent with this Policy or present unacceptable risk.

This Policy is reviewed periodically and may be updated to reflect changes in applicable laws, industry standards, partner requirements, and the evolving risk landscape.