Risk Appetite

Risk Appetite

Extract from Fincapital’s AML/CTF Risk Appetite Policy detailing the Prohibited and Restricted Business activities.

Purpose and Scope


Fincapital Partners AG is a Fincapial intermediary authorized in Switzerland.
The organization provides payment services to natural and legal persons. The purpose of this Anti-Money Laundering / Counter Terrorist Financing (“AML/ CTF”) Risk Appetite Policy (the “Policy”) is to define Fincapital’s risk tolerance and the guiding principles governing Money Laundering and Terrorist Financing (“ML/TF”) risk identification, measurement, reporting, management and monitoring, as required by applicable laws…

Accepted Business

As a general principle, Fincapital shall not onboard Clients carrying out businesses or activities that are illegal, conducted in absence of required licenses or permissions, or present an excessive reputational risk (which includes any material adverse media). 

Fincapital will not do business with persons, groups, legal entities, bodies, and similar which have been sanctioned for major offenses irrespective of when the Client was sanctioned and the jurisdiction(s) in which it was sanctioned.

However, in some circumstances the Onboarding Committee may approve such Clients undertaking a Risk Based Approach, depending on the facts and merits of the sanction.

Prohibited Client Types and Prohibited Payment Flows:

Fincapital does not permit pay in or pay outs from its accounts in physical cash. Fincapital does not onboard, nor will it process the payment flows for its PSP Clients, for the following:

Groups, legal bodies or similar subject to international sanctions or embargoes, in particular as issued by the Commission de Surveillance du Secteur Financier (“CSSF”), HM Treasury (UK),the European Union (“EU”), the United Nations (“UN”) or the US Office of Foreign Assets Control (“OFAC”) and other sanction lists;“Non-standard” or “non transparent” activities – those carried out through special-purpose or assimilated legal entities (special purpose vehicles) (structures) or in jurisdictions that impede transparency or which do not meet international banking standards;

Bidding fee auctions, penny auctions, or any type of all-pay auction in which all participants must pay a non-refundable fee to place each small incremental bid;

Shell banks; (banks based in countries where they have no physical presence involving decision-making and management and which are typically not connected to wider regulated financial groups);

Shell companies; (a company with no physical presence involving effective decision-making, operations or assets other than cash or equivalents of cash);

Bearer share corporations and companies connected to nominee or similar arrangements for the purpose of hiding or mask the true beneficial ownership (some trust structures may be permitted, depending on the merits of the case and there is no suggestion of untoward behavior);

Adult Services – this includes, but is not limited to, Escort services, Solicitation thereof, sale and/or advertising or suggestion of any physical sexual services that may imply or suggest prostitution, regardless whether it is legal in the specific country involved;

Unregulated or offshore holding/investment companies involved in managing or investing own- or third-party funds;

Any involvement in the sale or marketing of Binary Options;

Weapons of war, automatic weapons, ammunition or defense equipment: Includes merchants involved in the sales, intermediation or commerce of war or automatic weapons, including but not limited to chemical weapons, cluster bombs, ammunition, or other defense equipment or similar.Trade in tobacco, E-cigarettes and alcohol products;

Trade in arms and ammunition Activities related to art, cultural artifacts and other items of archaeological, historical, cultural and religious importance or rare scientific value, ivory and protected species;

Activities related to ferrous, non-ferrous and precious metals, stones and jewelry;

Banking (including private banking), investment, securities trading, insurance, currency exchange, money lending (including alternative lending options) and other financial activities 

Forex trading & Wealth management company

Oil and Mining Industry Religious organization 

Charity 

Dating and Adult Entertainment 

Gambling 

Pharmaceuticals High value dealership or trade Consultancy/Advisory, 

Pawn Brokerage 



Prohibited countries

Fincapital will not onboard clients nor make payments to the following countries:

Afghanistan
Albania
Anguilla
Antigua and baruda
Aruba
Bahamas
Bahrain
Barbados
Belarus
BVIBruneiBurkina Faso
Cambodge
Cayman island
Cook islands
Crimea & Donbass
Curaçao
Djibouti
Dominica
Ecuador
Fiji
Gibraltar
Guatemala
Guernsey
Haiti
Iran
Isle of man
Jamaica
Jordan
Kazakhstan
Kenya
Kyrgyzstan
Lebanon
Liberia
Maldives
Mali
Marshall island
Mauritius
Montserrat
Morocco
Myanmar
Namibia
Nauru
Nicaragua
Niue
North Korea
Pakistan
Palau
Panama
Philippines
Russia
St Kitts & nevis
St Pierre
Samoa
Senegal
Seychelles
St Maarten
Somalia
South Sudan
St Helen
Syria
Tadjikistan
Tonga
Trinidad & Tobago
Turkmenistan
Turks & Caicos
Uganda
USA
BVI
Uruguay
Vanuatu
Venezuela
Yemen
Zimbabwe