Acceptable Use Policy

Acceptable Use Policy

Last updated: October 24, 2022

By applying for, accessing or using services provided by Circle Internet Financial, LLC, Circle Payments, LLC, Circle UK Trading Limited and/or Circle International Bermuda Limited (together, “Circle”), inclusive of, but not limited to, Circle Account, Application Programming Interface products, card processing, and the Circle Yield offering (together and separately, the “Services”), you agree to be bound by this Acceptable Use Policy (“AUP”) and any additional terms, conditions, rules or policies that are provided to you in connection with the Services via the USDC User Agreement, Master Services Agreement, or otherwise (“User Agreement”).

This AUP is subject to change at any time without notice, and the changes will be effective when posted. Your continued use of the Services indicates your acceptance and agreement to the AUP changes.

1. Purpose. The purpose of this AUP is to (i) comply with relevant laws, banking partner requirements, and card or payment association (e.g., VISA, MasterCard, NACHA) rules and policies, (ii) specify to you what customers, merchants, activities/business types and transactions are considered prohibited use of the Services, (iii) to protect the integrity of our network, and (iv) to specify the consequences that may flow from violating these AUP requirements.

2. Prohibited Users. In addition to any eligibility requirements in the User Agreement, if any of the following apply to you, you are ineligible (or may become ineligible) to use our Services:

  • Your use of Services may cause us not to be compliant with relevant laws, sponsor bank requirements, and card or payment association (e.g. VISA, MasterCard, NACHA) rules and policies;
  • You are a resident, national or agent of Cuba, North Korea, Sudan, Syria, the Crimea region of Ukraine, or any other country to which the United States, United Kingdom, or Bermuda embargo goods (“Restricted Territories”);
  • You are on the Table of Denial Orders, the Entity List, or the List of Specially Designated Nationals, Her Majesty’s Treasury Financial Sanctions Target, or Bermuda Sanctions Regime List (“Restricted Persons”); or
  • You intend to transact with any Restricted Territories or Restricted Persons.


3. Prohibited Activities and Business Types. If you fall into one of the following categories and/or accept payment for the following prohibited activities, you are ineligible (or may become ineligible) to use our Services. For clarity, the following lists are not exhaustive and we may, at our sole discretion, modify them without notice:

Prohibited Business Type Description
Adult services Adult digital content, lingerie or passion parties, adult DVD rentals/sales, adult novelties, massage parlors (without licensed massage therapists), escort services, mail order bride services, dating/match-making services.
Auction services Online auction services and pawn shops.
ATM Operators Operators of privately owned ATMs, with the exception of crypto ATMs and kiosks.
Bankruptcy services Bankruptcy attorneys, collection attorneys, factoring companies, or liquidation services.
Controlled substances and drug paraphernalia Narcotics, prescription drugs, steroids, or related paraphernalia or accessories, unless licensed and authorized by the jurisdiction in which the customer is based as well as by the jurisdiction in which the transaction takes place. Equipment or material that is for the making, using, or concealing illegal drugs.
Court ordered payments Court ordered payments, structured settlements, tax payments, tax settlements
Credit repair services Credit repair services, loan repayment facilitators, credit counseling, credit protection, identity theft protection or other services that may present consumer protection risks.
Cyberlocking services Sale of devices that are designed to block, jam, or otherwise interfere with cellular and personal communication services, police radar, global positioning systems, and wireless networking services.
Debt collection Collection agencies and any business engaged in the collection of debt, including those associated with medical billing, or factoring companies.
Gambling Gambling activities including but not limited to sports betting, casino games, horse racing, dog racing, games that may be classified as gambling (e.g. poker), bookmakers, lotteries, bingo, internet gambling, off-track betting, card clubs, or other activities that facilitate any of the foregoing, unless licensed and authorized by the jurisdiction in which the customer is based as well as by the jurisdiction in which the transaction takes place.
Illegal activities Businesses or transactions that appear to relate to any form of illegal activity, including but not limited to, money laundering, terrorist financing, human trafficking or political corruption.
Intellectual property Goods or services that infringe or violate any copyright, trademark, or proprietary rights under the laws of any jurisdiction. This includes the sale of counterfeit items and unauthorized replicas or copies of items, and applies to items both actual and virtual in nature. Examples include (but are not limited to) counterfeit watches, handbags or accessories, and unauthorized copies of software programs, video games, music, movies, television programs, photographs and IDs. Upon Circle’s request, you must provide records about the authenticity of your products.
Precious metals and jewelry Sales of or dealers in precious metals (coins, bullion, etc.), precious stones, and fine jewelry.
Marijuana/CBD Marijuana as well as CBD in any form for sale for any purpose, including medicinal or homeopathic, regardless of legal status.
Multi-level marketing Pyramid and Ponzi schemes, multi-level marketing programs, wealth creation programs, paid-to-click schemes and other similar programs that are not traditional and legitimate advertising businesses.
Pay-day lenders Pay-day lending, short term cash loans, title loans, and cash advance services.
Ransomware Ransomware services, including cyber incident response and data-breach response.
Shell banks and financial institutions Banks or other financial institutions registered in a jurisdiction in which they have no physical presence.
Unlicensed money service businesses Any unlicensed money service business, including money transmitter and currency exchange.
Weapons Manufacturing, building or assembling weapons of any kind, including but not limited to, firearms, ammunition, knives, explosives, or related accessories.
Other businesses
  • Layaway systems and annuities.
  • Miracle cures, unsubstantiated remedies, or other items marketed as quick health fixes, designer supplements, nutraceuticals, muscle mass proteins, weight gain or loss supplements.
  • Sale of email or direct marketing lists enabling unsolicited contacts, such as from telemarketing merchants (inbound or outbound).
  • Sale of manuals, how-to guides, or equipment to disable, “hack”, or modify access controls on software, servers, phones, or websites, including but not limited to mod-chips, drive chips, or access cards.
  • Items or sites that encourage or promote hate, violence, or racial intolerance.
  • Psychic services.

 

4. Prohibited Transactions. Using the Services for transfers related to the following is prohibited, and Circle reserves the right to monitor for transactions that relate to:

  • Wash trading, front-running, insider trading, market manipulation or other forms of market-based fraud or deceit
  • Purchasing goods of any type from Darknet markets, or any other service or website that acts as a marketplace for illegal goods (even though such marketplace might also sell legal goods)
  • Money laundering
  • Terrorist financing
  • Processing transactions for another business other than the one listed on the account


5. Restricted Activities. In connection with your use of the Services, you hereby agree that you will not:

  • Violate (or assist any other party in violating) any applicable law, statute, ordinance, or regulation
  • Intentionally try to defraud (or assist in the defrauding of) Circle or other Circle users
  • Provide false, inaccurate, or misleading information
  • Take any action that interferes with, intercepts, or expropriates any system, data, or information
  • Partake in any transaction involving the proceeds of illegal activity
  • Transmit or upload any virus, worm, or other malicious software or program
  • Attempt to gain unauthorized access to other Circle Accounts, the Circle website, or any related networks or systems
  • Use the Services on behalf of any third party or otherwise act as an intermediary between Circle and any third parties
  • Collect any user information from other Circle users, including, without limitation, email addresses
  • Defame, harass, or violate the privacy or intellectual property rights of Circle or any other Circle users
  • Upload, display or transmit any messages, photos, videos or other media that contain illegal goods, violent, obscene or copyrighted images or materials

6. Commercial Entity Agreement. Circle may offer various payment processing services as part of the Services.  These services may include credit and debit card processing services.  Additional terms and conditions set forth in the User Agreement apply to such services. If your credit or debit processing activity utilizing the Services reaches certain thresholds or involves certain business segments, geographies or activities, you are required by the card networks and/or Circle’s processing partners to agree to a Commercial Entity Agreement to allow you to accept or continue accepting card payments. In this case, the Commercial Entity Agreement will apply to any card payment processed by Circle on your behalf and will form part of this AUP and your User Agreement and be incorporated herein and therein by reference.

7. Compliance Monitoring; Violations of this Policy. We will monitor your transactions and activities for potential violations of this AUP. Monitoring includes, but is not limited to, reviewing your accounts for retrievals, returns, or Chargebacks, as well as using third-party information or sources. We encourage you to contact us if you believe you may be in violation of this AUP. We reserve the right, per the terms of the User Agreement to take any corrective action (with or without notice to you) as we deem necessary to mitigate our risk or ensure compliance with this AUP, including but not limited to: (i) blocking or withholding a transaction; (ii) holding funds associated with a prohibited transaction; (iii) suspending, restricting, or terminating your use of the Services, or (iv) subjecting you to applicable fines, assessment, expenses and fees.