Legal & Privacy

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:

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.