Revised August 13, 2025

The examples listed below are not exhaustive and we reserve the right to modify or update the lists below at any time by posting a revised version to our website. The revised version will be immediately effective upon posting.

Prohibited Activities List
If we determine in our sole discretion that you engage or have engaged in the activities listed below, or are authorizing, facilitating, or helping others to do so, or otherwise are engaged in activities that are illegal, may harm others or our reputation or operations, or violate our or others’ rights, we may deny, terminate, or suspend your use of the Services:

• Any activity which would violate any law, statute, ordinance, regulation, or sanctions programs applicable in the countries where Modu and its third-party partners conduct business, including but not limited to Kazakhstan regulatory requirements;
• Utilizing identities that cannot be verified, applying anonymously or under fictitious names, and/or having accounts that do not identify the owners or stock certificates held in accounts without an owner endorsed to the "bearer";
• Using a business account for personal spend;
• Third-party payment processing, including but not limited to facilitating or processing payments for, or on behalf of, a third party;
• Any activity where there is a suspicion or evidence that criminal activity has taken place, a criminal offense has been committed, or where there is a suspicion of terrorist financing;
• Any activity involving the use of shell banks (entities that have no physical existence in the country in which it is incorporated and licensed) or banks with no physical presence in any country that are not licensed by any banking authority;
• Using accounts to facilitate Money Services Businesses (e.g., money/currency exchange, money transfer, cheque cashing, travelers cheques, money orders or stored value cards that meet the regulatory definition);
• Any activity that involves any gambling, bet, wager, lottery, sweepstakes, or game of chance which is unlawful under applicable law, including the development of gambling software or hosting environments;
• High risk and high interest rate loans and/or payday loans;
• Missions, embassies and consulates;
• Marijuana-related activities, including medical marijuana, such as manufacturing, dispensing, transporting, and/or otherwise deriving revenue from marijuana-related activity;
• Sexually-related services including escorts, prostitution, adult entertainment, pornography (child or adult), obscene media companies, and other sexually related online services such as adult live chats, sexually motivated dating services, and pornographic pay per view services;
• Illicit drugs trafficking, drug paraphernalia manufacturing, or illicit drug distribution, including providing tools or services to aid in illicit drug trafficking or distribution;
• Production, sale, or distribution of controlled substances without a pharmaceutical license;
• Business models indicative of a ponzi scheme, pyramid selling, pump and dump schemes, or other forms of “get rich quick,” unfair, or deceptive business models;
• Promoting, supporting, or perpetuating terrorism, hate, bigotry, racism, abuse, harassment, discrimination, violence, or physical harm against any group based on race, religion, disability, gender, sexual orientation, gender identity, national origin, immigration status, any immutable characteristic, or any legally protected characteristic under applicable law;
• The production, purchase, sale, distribution, trading or manufacturing of guns, firearms, other weapons, ammunition, or explosive devices;
• Sale of non-anonymized and non-aggregated consumer data;
• Manufacturing of counterfeit goods or goods meant to infringe on intellectual property rights;
• Trade, sale, or distribution of illegal products or products or services that are imported or exported illegally; and
• Activities involving pseudo-medical and pseudo-pharmaceutical companies.

The following are not eligible for a Modu account: Securities brokers or broker-dealers.

Restricted Activities List
If we determine in our sole discretion that you engage or have engaged in the activities listed below, or are authorizing, facilitating, or helping others to do so, you may be required to provide additional information or documentation or may be ineligible for certain Services:

• Dealing in cryptocurrency, digital assets, or digital currency;
• Licensed financial services, including those of banks or bank affiliates, money transmitters, investment companies, or investment funds;
• Production, sale, or distribution of "gray market" goods or services;
• Production, sale, or distribution of certain controlled substances with a pharmaceutical license;
• Activities that Modu, in its sole discretion, identifies as high-risk.

Please contact us if you are unsure whether your business or activities are permitted by Modu.