Treasury Management Terms and Conditions

Last updated May 28, 2024

These Treasury Management Terms (these “Treasury Management Terms”), together with the Terms of Service Agreement available at (the “Universal Terms” and, together with these Treasury Management Terms, the “Treasury Management Agreement”), set forth the terms and conditions under which Asure Customer & IP HoldCo LLC (including any applicable affiliate, “Provider”) agrees to provide to User and, if applicable, User’s customers utilizing the Treasury Management Service (each a “User Customer”) certain payroll services, service bureau process and other related services and functions as set forth on the applicable Sales Order (the “Treasury Management Service”).


These Treasury Management Terms are “Service Terms” under the Universal Terms. Capitalized terms used but not otherwise defined in these Treasury Management Terms shall have the meanings ascribed to such terms in the Universal Terms. The Treasury Management Agreement is a legally binding agreement between User and Provider. User is encouraged to read the Treasury Management Agreement carefully and to save a copy of it for User’s records. If User is agreeing to these Treasury Management Terms on behalf of a business or an individual other than User, User represents and warrants that User has authority to bind that business or other individual to the Treasury Management Agreement, and User’s agreement to these terms will be treated as the agreement of such business or individual. In that event, “User” (as defined in the Universal Terms) also refers to that business or individual. By (i) executing the applicable Sales Order for Treasury Management Service, or (ii) accessing or using the Treasury Management Service, User accepts the Treasury Management Agreement, and User agrees, effective as of the date of such action, to be bound by the Treasury Management Agreement.


  1. Treasury Management Terms Governed by Universal Terms.


The terms and conditions of the Universal Terms agreed to in connection with the execution of the Sales Order, including but not limited to all representations, warranties, covenants, disclaimers, limitations on liability, agreements, and indemnities relating to the Services, are incorporated herein by reference, and User acknowledges and agrees that the representations, warranties, covenants, disclaimers, limitations on liability, agreements, and indemnities contained in the Universal Terms shall remain in full force and effect to the full extent provided therein.


If the terms and conditions of these Treasury Management Terms conflict with the terms and conditions of the Universal Terms, the terms and conditions of these Treasury Management Terms shall control with respect to the provision of the Treasury Management Service.




  1. License.


Provider grants User a limited, non-exclusive, non-transferable license to access, use and sell the Treasury Management Service through its Authorized Users during the Term (the “License”); provided, however, that User shall not impound User Customer funds, remit payments to any relevant government authorities, prepare and file returns on behalf of User Customers, or conduct any other actions that would result in User being characterized as a Third-Party Service Provider or a Nested Third-Party Service Provider (as such terms are defined in the NACHA Rules). User acknowledges that it does not have the right to, and shall not permit User Customers to, grant to any third party a sublicense to any right, title, or interest in or to the Treasury Management Service. Provider will provide, via electronic download, user guides and all other materials necessary for User to use the Treasury Management Service (collectively, the “Treasury Management Documentation”). User may only copy the Treasury Management Documentation for its internal business use to satisfy its reasonable internal needs and may not disseminate such Treasury Management Documentation to third parties.



The Treasury Management Service contains trade secrets of Provider and its suppliers, and User agrees to protect these trade secrets with as much care as User protects its own trade secrets and, in any event, at least with reasonable care. Title to the Treasury Management Service and all rights are reserved to Provider and its suppliers. User does not acquire any rights, express or implied, in the Treasury Management Service other than those specified in the Treasury Management Agreement. Any unauthorized use of the Treasury Management Service will be deemed to be a material breach of the Treasury Management Agreement. Without limiting the foregoing, use of the Treasury Management Service for internal development, quality testing, or any other non-production purpose is not authorized under the Treasury Management Agreement.


  1. Payroll Services.


Provided that User meets User’s payment obligations and complies with the terms of the Treasury Management Agreement, Provider will provide User with the Services for the purposes of (i) processing payroll and making related payroll payments for User Customers; (ii) making certain payroll tax payments and payroll tax filings electronically for User Customers; (iii) if requested, making certain payments related to workers’ compensation, 401(k), or any other similar deductions and (iv) if applicable, sending wage garnishments, such as child support payments, to applicable local, state, or federal agencies for User Customers. In performing the Services, including for each of the foregoing purposes, Provider will rely on the information furnished by User, the Authorized Users or any authorized representatives, and Provider is not responsible or liable for any errors resulting from such reliance (or any penalties or interest incurred in connection with such errors), as further described in Section 12 (Warranties and Limitations of Liability) of the Universal Terms. User may not use the Services on a professional basis for anyone other than User.


Prior to the initial payroll processing date for each User Customer, User must submit the completed and executed documents Provider requires for providing the Treasury Management Service, including the applicable User Customer’s payroll and bank account information, any required federal, state, or local powers of attorney, and any additional information requested by Provider. The Treasury Management Service provided will be based on and is dependent upon information provided to Provider by User (including proof of federal, state, and local tax identification numbers) for each User Customer. Failure to provide the required documents may adversely impact Provider’s ability to perform the Treasury Management Service. User is also responsible for ensuring that each User Customer: (i) deposits any federal, state, and local withholding liabilities incurred prior to the provision of any payroll services by Provider; (ii) submits any and all payroll returns to tax agencies (state, federal, and/or local) that were due for payroll tax liabilities incurred prior to the provision of any payroll services by Provider; and (iii) cancel any prior payroll service or services of professional employee organizations/employee leasing companies prior to the provision of any payroll services by Provider.


In performing the Reseller Payroll MM Service, User acknowledges and agrees that (i) Provider is not acting in a fiduciary capacity for User and/or User’s business; (ii) using the Treasury Management Service does not relieve User of User’s obligations under local, state, or federal laws or regulations to retain records relating to User’s data contained in Provider’s files; and (iii) any information that Provider provides in connection with the Treasury Management Service is for informational purposes only and should not be construed by User as legal, tax, or accounting advice.


  1. Payroll Account.


An Authorized User shall approve and submit the Entry Information (as defined below), thereby authorizing Provider to create and transmit credit or debit entries (the “Entries”) necessary to process each User Customer’s payroll transactions. User acknowledges that it is solely responsible for all Entry Information provided to Provider. User agrees to implement and maintain reasonable safeguards to protect against: (i) any unauthorized access to confidential information being stored, processed, or transmitted in connection with Entries, and (ii) submission of fraudulent Entries purportedly on User’s, or User Customers’, behalf.


  1. Entry Information.


Entry Information” means any information provided to Provider in connection with the Treasury Management Services, including but not limited to information provided by User, Authorized Users, authorized representatives, User’s employees, or User’s independent contractors, including, but not limited to, the information used to calculate and pay each User Customer’s employee payroll, track each User Customer’s defined employee benefits, pay each User Customer’s payroll taxes to applicable taxing agencies (including User Customer’s employer identification number(s), unemployment insurance tax rates, and employment tax deposit schedule), produce payroll tax returns and W-2 statements, and print checks for each User Customer on User’s Online Account (if applicable).


Provider will notify User when all information necessary to begin the Treasury Management Services has been received and the enrollment process for the Treasury Management Services has been completed. Prior to submitting each User Customer’s first payroll, User shall review the Entry Information for completeness and accuracy. User must correct or provide, respectively, any incorrect or missing Entry Information. User is fully responsible for the accuracy of all information User provides, submits, and/or approves (whether provided directly or through Authorized Users or authorized representatives), and User is solely responsible for any Claims, including but not limited to Internal Revenue Service (“IRS”) penalties and/or interest, and other penalties and/or interest arising from the failure to timely provide and maintain accurate and complete Entry Information at all times.


User agrees that by submitting each payroll (including the first payroll) for each User Customer that: (i) User approves all Entry Information; (ii) User represents and warrants to Provider that no Entry Information submitted to Provider will result in Entries that would violate the sanctions program of the Office of Foreign Assets Control of the U.S. Department of the Treasury or any other applicable laws, rules, or regulations; (iii) User waives and releases any Claim against Provider arising out of any errors or omissions in the Entry Information which User has not corrected (whether directly or through Authorized Users or authorized representatives) or has not requested Provider to correct; and (iv) User acknowledges that any subsequent request for corrections will be considered special handling, and additional fees may be charged. Final responsibility for any audits or assessments rests with User. Provider will not have any responsibility for verifying the accuracy of any data User provides.


User acknowledges, agrees, and understands that (i) any information or instructions (including but not limited to Entry Information and Entries) communicated to Provider by User, an Authorized User, or an authorized representative (or anyone that Provider reasonably believes to be User, an Authorized User, or an authorized representative) will be deemed fully authorized by User, and User shall be fully responsible for the accuracy of such information and instructions, and any Claims, including but not limited to any IRS penalties and/or interest or other penalties and/or interest arising therefrom; and (ii) notwithstanding such deemed authorization, Provider may in its sole discretion refuse to accept or act upon any such instructions.


Provider, its employees, and agents will only collect, use, and disclose data furnished by User or produced by Provider under this Agreement in accordance with Provider’s Privacy Policy.


  1. Payroll Authorization.


Provider will use reasonable efforts to verify that anyone providing an instruction to approve, release, cancel, or amend the Entry Information used to create Entries (each, a “Payment Order”) to be originated by Provider is either User, an Authorized User, or an authorized representative. Provider does not verify or review Payment Orders for the purpose of detecting any errors; it is User’s responsibility to verify the accuracy of Payment Orders. User will be bound by any Payment Order that is received by Provider in compliance with this designated authorization procedure, and User shall indemnify and hold Provider and the other Indemnified Parties harmless from and against any Claims arising from the execution of a Payment Order in good faith and in compliance with such procedures.


If a Payment Order describes the payee inconsistently by name and account number, (i) payment may be made on the basis of the account number even if a User Customer identifies a person different from the named payee; or (ii) Provider may, in its sole discretion, refuse to accept or may return the Payment Order. If a Payment Order describes a participating financial institution inconsistently by name and identification number, the identification number may be relied upon as the proper identification of the financial institution. If a Payment Order identifies a non-existent or unidentifiable person or account as the payee or the payee’s account, Provider may, in its sole discretion, refuse to accept or may return the Payment Order.


  1. Returns and Erroneous Entries.


Provider will notify User in writing in the event an Entry is returned. Unless the Entry is corrected (if applicable) and resubmitted by User, Provider has no obligation to retransmit a returned Entry. Provider in its sole discretion can suspend the processing of any Payment Order and electronic submission of Entries if User or a User Customer has a return rate that exceeds the threshold established by the NACHA Rules. If an offsetting debit is returned unpaid, Provider may assume that the associated credits were erroneous, and User shall grant Provider permission to revert such Entries, at the User’s expense.


If User discovers that any Entry it has initiated is erroneous, it must notify Provider of the error immediately. In such a case, Provider will initiate an adjusting Entry, if possible.


  1. Technical Expertise.


User represents that it has and will maintain the technical expertise to accurately calculate and transmit payroll processing data and related Entry Information for itself and the User Customers (the “Master File”) to Provider. Provider shall supply to User the required procedures, specifications, and format for payroll data and transmissions. For the avoidance of doubt, the Master File must include the fees that each User Customer owes to the User and if User fails to provide such fees, User shall be liable for any damages that arise in connection with such failure.


  1. Master File and Set Up.


User shall maintain and transmit the Master File to Provider in order for Provider to process payroll in a method compliant with all governmental authority requirements. User must submit the Master File a minimum of four (4) banking days prior to the first payroll check date to be processed by Provider. Late set ups/installations shall be subject to additional fees. User must verify the accuracy of each submitted Master File with the User Customers and is responsible for the accuracy of such Master File.


  1. Required Forms.


User shall, and shall also require each User Customer to, complete any and all documentation required by Provider at Provider’s discretion to ensure compliance with any and all federal, state, or local laws, rules, or regulations, or requirements of its banking partners or NACHA, including but not limited to Anti-Money Laundering/Bank Secrecy Act (“AML/BSA”) laws, “Know Your Customer” rules, and OFAC rules and regulations, including, but not limited to: (i) IRS Form 8655 (Reporting Agent), (ii) IRS Form 8821 (Tax Information Authorization), (iii) IRS Form 2848 (Power of Attorney), (iv) any required State power of attorney form, (v) the ACH Authorization Agreement provided by Provider, and (vi) Provider’s AML/BSA “know your customer” compliance documentation in place from time to time or as modified. Provider has no obligation to provide services if User, on behalf of the User Customers, has not provided accurate and complete payroll and tax data. Provider has no obligation to provide services unless each applicable User Customer has funded their designated bank accounts with amounts necessary to cover all required payroll payments under the Treasury Management Agreement, no later than 5:00 pm Central Time two (2) full banking days prior to each scheduled payroll date (“Funding Deadline”). In no event may User enter into a contract with a User Customer that includes a funding date deadline that is later than the Funding Deadline. In the event that sufficient funds are not included in the designated bank accounts as of the Funding Deadline, User shall be liable for any fees, costs, or expenses incurred by Provider in connection with such insufficient funds.


  1. User Customer Registration/Enrollment.


User hereby accepts responsibility for and shall cause all User Customers to register with applicable federal, state, and/or local taxing authorities for Employer Identification Number(s) and electronic pay and file service where required. User shall include all tax authority PINs in the Master File. Failure to provide relevant Employer Identification Number(s) and/or tax authority PINs voids Provider’s responsibilities hereunder.


  1. Processing Responsibilities.


User shall transmit to Provider all payroll data files in accordance with Provider’s current specifications. User agrees to implement any updates to Provider’s specifications within four (4) weeks of receipt of each published revision. User agrees to transmit the required payroll data files to Provider prior to the Funding Deadline. Late receipt of said payroll data is subject to is subject to applicable late fees set forth on the applicable Exception Fee schedule located at and as may be amended from time to time (the “Exception Fee Schedule”).


Provider’s obligation to perform its services hereunder in a timely manner is contingent upon: (i) the accuracy of the payroll data and Master File; (ii) the transmission and timely approval of all payroll data files by User; and (iii) the successful collection of funds to cover any payroll liabilities. Any penalties and interest which result from errors or omissions of User or User Customers shall be the responsibility of User. User, and not Provider, has full liability for unfunded amounts for payroll liabilities, plus fees, costs, penalties, and interest. In the event of a non-sufficient funds (“NSF”) transaction in User’s Bank Account or a User Customer, Provider will contact User and Provider will debit User’s account for the unfunded amounts including penalties associated with NSF charges as set forth on the applicable Exception Fee Schedule, plus all applicable bank fees incurred any time after Provider receives notice of the NSF. User, and not Provider, is responsible for all NSF bank fees and penalties and unfunded payroll amounts. User shall indemnify and hold Provider and the other Indemnified Parties harmless from and against any Claims arising from an NSF by User or any User Customer.


  1. File Approval.


User acknowledges and agrees that all payroll files transmitted to Provider require the approval of User. If User fails to approve the file transmitted, User directs Provider to place such payroll file on hold and to refrain from processing the files until Provider receives User approval.


  1. User Customer Account Reconciliation.


Provider will be responsible for ensuring that the account designated by each User Customer on the applicable “ACH Authorization Agreement” from which payroll or wage garnishment liabilities are impounded is reconciled and that all funds of User Customers are accounted for.


  1. Payroll Tax Services; Employee Direct Deposit Services.

User delegates authority to Provider (and its affiliates) to pay appropriate payroll taxes and file payroll tax returns on each User Customer’s behalf (“Provider Tax Services”). This authority includes, as applicable federal, state and most local taxing jurisdictions designated by User on behalf of each User Customer. Provider agrees to file these returns with the appropriate taxing authority in a timely manner. User is responsible for providing Provider with all appropriate documentation including without limitation account numbers, filing frequency, payment methods, filing methods and rates for each User Customer. A User Customer must affirmatively elect not to receive Provider Tax Services. If a User Customer elects not to receive Provider Tax Services, Provider will not pay any payroll taxes or file any payroll tax returns on behalf of a User Customer and User acknowledges and agrees that Provider shall have no responsibility or liability in connection therewith.

Provider shall have no responsibility or liability for performance (including tax deficiencies, penalties, or interest charges) with respect to a User Customer if such User Customer has not provided (i) necessary powers of attorney, (ii) accurate, current, and adequate User Customer data and information to make the necessary payroll tax payments or tax filings or provides erroneous User Customer data or information, or (iii) sufficient funds in such User Customer’s designated bank account to cover such payroll tax obligations or employee deposits.

Provider will assume responsibility for late payments to the degree that the error was caused by Provider. Responsibility for penalties or interest charges will only be accepted for those incurred in the quarter or portion of the quarter when Provider begins its function as tax agent. The responsibility will end when Provider ends its function as tax agent. It is also understood that errors or faulty returns may be caused by inaccurate information provided to Provider by User, User’s staff, accountants, or other involved parties. If such is the case, Provider may be willing to help rectify the situation, but will not be responsible for any resultant tax deficiency, penalty, or interest charges. Additional fees may be charged by Provider to rectify such errors. For the avoidance of doubt, nothing contained in the Treasury Management Agreement relieves User or any User Customer of any tax liabilities or the payment of employee deposits. User shall be obligated to pay immediately any User Customer tax liabilities or employee deposits incorrectly computed, under withheld, or otherwise incorrectly processed, whether or not those tax liabilities or other processing errors are a result of the actions or inactions of Provider.

Each User Customer employee who is eligible and desires to use the direct deposit services set forth in the Treasury Management Agreement will authorize User, User Customer and Provider to initiate paperless credits for sums due and payable to him/her for deposit at the participating bank where his/her deposit account is maintained, hereinafter called “receiving bank”. Such authorization will also authorize User, the applicable User Customer and Provider to initiate either paper or paperless debits for sums due to a User Customer for erroneous credits or deposits at the receiving bank as governed by NACHA rules. User shall deliver to Provider signed copies of each applicable User Customer’s employee’s direct deposit authorization forms. User shall be solely responsible for ensuring that all account information for such employee remains current and correct and, in the event employee changes banks or accounts, User shall deliver an updated authorization form for such employee to Provider. User will retain all authorizations for a minimum of two (2) years following termination or revocation of the authorization.

As required by the federal government, Provider will utilize the Electronic Federal Tax Payment System (“EFTPS”) to deposit each User Customer’s employment taxes. It is User’s sole responsibility to notify Provider as to whether any User Customer is required by law to utilize this payment procedure. If a User Customer is required to file and/or pay state and local taxes electronically, and is not registered, and Provider must resort to a manual option to pay a User Customer’s taxes, any additional costs or fees charged or incurred will be paid by User. In addition, each User Customer shall comply with and be subject to NACHA rules and rules of the originating bank governing electronic funds transfer as such rules shall be in effect among participating banks and the Federal Reserve Bank. Provider will utilize the NACHA system to transfer funds between User Customer and Provider.

User agrees Provider will withdraw the aggregate total of all payroll taxes from the applicable User Customer’s designated bank account on the date that is the Funding Deadline. These funds will be held by Provider until such taxes are due by state, local, and federal regulations. Should funds be inadequate or should a bank reversal occur due to insufficient User Customer funds being available, Provider shall have no liability for late tax payment all of which shall be User’s liability. Additionally, at Provider’s option Provider may terminate a User Customer’s tax Services, employee direct deposit Services and payroll Services without notice which will be null and void. Further, Provider at its option may withhold payment of taxes due until the funds are made available. No interest is earned and payable to a User Customer on any funds held by Provider. All amounts earned on such funds while held by Provider will be for the sole account of Provider.


  1. Non-Compete.


During the term of this Treasury Management Agreement and for a period of twelve (12) months following the expiration of the Term, (i) Provider shall not, directly or indirectly, offer or provide payroll processing services to the User Customers and (ii) User shall not, directly or indirectly, offer or provide any payroll processing services or any other products or services competitive with Provider to any of the Provider’s customers.


  1. User Obligations.


User may enable access of the Treasury Management Service for use only by Authorized Users and solely for the business purposes set forth in the Treasury Management Agreement. User is responsible for any and all actions or inactions taken with or without User’s knowledge or consent by Authorized Users in connection with the Treasury Management Service or the Treasury Management Agreement. Any such action or inaction of an Authorized User that would result in a breach of the Treasury Management Agreement, if undertaken by User, will be deemed a breach of the Treasury Management Agreement by User. User shall: (i) have sole responsibility for the accuracy, quality, and legality of all User Customer data and for obtaining all consents and permissions required for the use thereof in connection with the Treasury Management Service; (ii) prevent unauthorized access to, or use of, the Treasury Management Service; (iii) notify Provider promptly of any such unauthorized access or use; (iv) be solely responsible for verifying the identity, bank account, and credit of each User Customer and verifying that each User Customer has sufficient credit; (v) include within any agreement between User and User Customer language stating that any fees owed to User by User Customer will be debited from each User Customer’s account by Provider and (vi) be solely responsible for making available employee paystubs or an equivalent statement to employees. User shall not: (a) use the Treasury Management Service in connection with committing tax fraud or otherwise in violation of applicable laws; (b) send or store obscene, threatening, or otherwise unlawful or tortious material, including material that violates privacy rights, or material that infringes upon or violates any patent, copyright, trade secret, trademark, or other intellectual property right of any third party; (c) send, upload, or otherwise provide or store malicious code; (d) interfere with or disrupt the integrity or performance of the Treasury Management Service or the data contained therein; (e) violate or tamper with the security of any of Provider’s computer equipment or software or attempt to gain access to the Treasury Management Service or its related systems or networks; (f) insert or allow any data to be inserted relating to a person who is not physically residing in the United States or who does not have a Social Security Number or other US-issued identification number for tax purposes; or (g) engage in the transfer of funds or the transmitting of currency or funds, or the value of currency or funds, by any means through a financial agency or institution, a Federal Reserve Bank or other facility of one or more Federal Reserve Banks, the Board of Governors of the Federal Reserve System, or both, or an electronic funds transfer network.


Any person that owns 10% or more of the equity interests of User (each a “Guarantor”) shall, jointly and severally, unconditionally and irrevocably, guarantee User’s payment and indemnification obligations in the Agreement. Each Guarantor shall acknowledge and agree to their aforementioned guarantee obligations by executing the Sales Order.


  1. User Trademarks.


User grants Provider a non-exclusive, non-sublicensable, non-transferable license during the Term to use any colors, logos and trademarks provided by User (collectively, “User Marks”) solely for purposes of providing User with a “private label” version of the Treasury Management Service and Treasury Management Documentation. All use of the User Marks shall be subject to User’s prior written approval and trademark usage guidelines in effect from time to time and shall inure to the benefit of User. Upon termination of this Treasury Management Agreement, this license shall automatically terminate and Provider shall cease all use of the User Marks. Except for the limited license granted in this Section, User retains all right, title and interest, including all intellectual property rights, in and to the User Marks.


  1. Insurance.

User agrees to maintain each of the following insurances (User shall provide to Provider a certificate of insurance evidencing such insurance prior to commencing the Treasury Management Service; such insurance coverages shall be independent of the indemnity provisions of the Agreement, and are not designed solely to guarantee payment of User’s indemnity obligations): (a) Commercial General Liability Insurance with a minimum limit of $1,000,000 per occurrence and in the aggregate for Bodily Injury and Property Damages; (b) Professional Liability Insurance providing not less than $3,000,000 coverage; (c) Cyber Liability Security Insurance providing not less than $5,000,000 coverage; and (d) Commercial Crime coverage with aggregate limits of at least $1,000,000 and include blanket coverage for Employee Dishonesty and Computer Fraud, for loss or damage arising out of or in connection with any fraudulent or dishonest acts committed by the employees of User, acting alone or in collusion with others, including the property and funds of others in their possession, care, custody, or control.


The limits specified above, may be satisfied with a combination of primary and Umbrella/Excess Insurance, such Umbrella/Excess Liability Insurance shall follow form of underlying policies.  User shall provide Provider with thirty (30) days’ written notice prior to the effective date of any cancellation or material change of the insurance.  All self-insured retentions and deductibles shall be the responsibility of and to the account of User.


  1. Financial Institution Requirements.


User acknowledges and agrees that Provider’s banking institutions impose certain requirements on Provider in connection with Provider acting as a “Third Party Sender” and the banking institutions acting as “Originating Depository Financial Institutions” in connection with the PTM Reseller Service. Such banking institutions (each an “ODFI”) and NACHA require that Provider’s Users, and User Customers, agree to the following contractual requirements:


  • Prohibited Businesses. User agrees that neither it, nor the User Customers, may be engaged directly or indirectly in any of the below listed prohibited business or industries at any time during the Term. User shall notify Provider in writing at least thirty (30) days prior to engaging in any of the prohibited businesses or industries. Engaging in a prohibited business or industry will be a material breach by User of the Treasury Management Agreement allowing Provider to terminate the Treasury Management Agreement without notice.


  • Businesses connected to very high-risk jurisdictions (see below)
  • Businesses that support manufacturing of assault weapons, bump stocks or high-capacity magazines
  • Businesses that support pornography or adult industry
  • Businesses that support payday lending
  • Businesses that support cannabis-related activities
  • Businesses that support online gambling
  • Businesses that support digital assets (e.g., cryptocurrency, online in-game assets, privacy tokens, NFT, etc.)
  • Non-bank financial institutions (“NBFI”) that support physical cash or cash equivalent (e.g., pre-paid cards, travelers check, etc.) products
  • Businesses peripherally involved in the manufacture, distribution of recreational weapons (e.g., hunting rifles, shotguns, archery)
  • Company, executive officer or relevant party subject to criminal investigation/regulatory proceeding
  • Sovereigns, sovereign wealth funds, government entities/agencies, military and supranational relationships due to political exposure
  • Businesses undergoing (chapter 11) restructuring bankruptcy
  • Financial institutions including banks, money service businesses (“MSB”), payment service providers (“PSP”) and NBFIs
  • Businesses that primarily support socially controversial activities and/or with the potential for elevated reputational risk, like:
    • Debt collection; patent trolling; vaping; private prisons; immigration detention centers; animal testing; mining; multilevel marketing firms; and companies that engage in predatory lending
  • Other businesses that pose elevated AML & regulatory risk, including:
    • Casinos with physical locations; non-profits or charitable organizations and foundations; waste management; pawn brokers; cash-intensive businesses; businesses involved in the import and export of physical goods, the sale of art or antiques, and the sale of jewelry/precious metals
  • Businesses that support and/or enable payments and other financial activities on behalf of their clients, including affiliates (e.g., inter-company, subsidiaries, etc.), financial institutions, banks, credit unions, money service businesses, third party payment processors, marketplaces, law firms and unlicensed financial institutions