Prohibited and restricted activities

1. Principles

TrustChange only serves lawful activities, carried out in good faith and accurately declared. This list derives from the AML/CFT policy, applicable regulations and the rules set by Mobile Money operators and our payment partners.

Assessment is based on the actual activity: the trading name, declared website or description provided do not change how an activity is classified. The customer remains responsible for what it sells, including when acting on behalf of a third party.

If you are unsure about your activity, write to contact@trustchange.fr before any transaction. A written answer constitutes TrustChange's position for the activity described.

2. Prohibited activities

No transaction is accepted for the following activities, whatever the country, amount or payment method:

• Gambling and games of chance: online casinos, sports betting, lotteries, paid raffles, scratch games, quizzes or contests requiring a stake, sale of betting "coins" or credits.
• Adult content and services: pornography, sale of sexual media, webcams, escort or paid dating services, any form of sexual exploitation.
• Unauthorised investments and trading: platforms promising returns, forex, CFDs, binary options, managing funds on behalf of third parties without a licence, Ponzi schemes, pyramid selling, "money doubling" schemes.
• Illegal streaming and downloading: pirate IPTV, resale of shared or misappropriated subscriptions, distribution of works without rights.
• Counterfeit goods and any sale infringing third-party intellectual property rights.
• Illegal goods and services: narcotics and controlled substances, unauthorised medicines, weapons, ammunition, explosives, protected species, organs, stolen goods.
• Forged documents and data: fake identity papers, fake diplomas or certificates, sale of personal data, accounts or credentials, hacking tools, malware, services bypassing identity verification.
• Unauthorised financial services: money transfer, manual or online currency exchange, collecting funds for undeclared third parties, lending without a licence, cash-out services, use of the service as a pass-through account.
• Funding of sanctioned organisations or persons, terrorism or the proliferation of weapons of mass destruction.
• Hateful, violent or extremist content, incitement to discrimination or violence.
• Fraud and deception: phishing, fake shops, fictitious sales, romance or investment scams, blackmail, fake donation appeals.
• Anonymous accounts or accounts opened under a fictitious or assumed name, and any attempt to circumvent identity verification.

3. Restricted activities (prior approval)

The following activities are only accepted with TrustChange's written approval, after enhanced due diligence. Approval may come with limits, a reserve or specific conditions, and may be reviewed at any time:

• Collecting payments on behalf of third parties (marketplaces, resellers, platforms): each beneficiary must be identified and declared before activation.
• Associations, NGOs, religious organisations and fundraising: legal existence and use of funds must be evidenced.
• Video games with randomised purchases (loot boxes) and internal virtual currencies.
• Resale of airtime, data bundles or telecommunication services.
• Online training, paid coaching and recurring subscriptions.
• Health products, food supplements and cosmetics with therapeutic claims.
• Alcohol and tobacco, in compliance with local laws and the legal minimum age.
• Travel, ticketing, bookings and prepayments for services delivered later.
• Any activity whose expected monthly volume exceeds the enhanced due diligence thresholds set by TrustChange.
• Use of the integrator API to collect on behalf of a business: the company, its legal representative and its website must be verified.

4. Procedure in case of breach

Where TrustChange identifies or suspects a prohibited activity, or a restricted activity carried out without approval, it may, as a precautionary measure and without notice, lock all or part of the account, suspend transactions and hold funds during the review.

The customer then receives a written formal notice stating the facts and granting a deadline, generally 24 to 72 hours depending on severity, to provide explanations and undertake in writing to cease the activity.

• Explanation accepted: the measures are lifted, with or without conditions.
• No answer, insufficient explanation or repeated breach: the account is permanently closed, without compensation.
• Proven fraud, confirmed sanctions match, terrorist financing or an order from an authority: immediate closure, without formal notice.

TrustChange may also report the facts to its payment partners and the competent authorities, without informing the customer where the law prohibits it.

5. Treatment of funds

Amounts received in connection with a prohibited activity are not paid out to the customer until their lawful origin is established. Depending on the case, they may be refunded to payers, retained to cover fees, penalties and losses incurred by TrustChange or its partners, or held at the disposal of the competent judicial or administrative authorities.

6. Changes to this list

This list evolves with regulations, operator rules and observed risks. Customers concerned are informed in advance of any newly prohibited activity, except in an emergency arising from a legal obligation or a partner requirement.