Prohibited and restricted businesses

Prohibited

Cloove will not support the activity. Not with additional checks, not with limits, not on an exception. An application is declined and an existing relationship is terminated.

Restricted

The activity is lawful and Cloove can support it, but it carries elevated risk, so it goes through additional review before approval and operates on conditions afterwards: tighter limits, closer monitoring, a shorter review cycle, or evidence of a licence.

Everything else

Permitted. Ordinary onboarding, ordinary monitoring.

The default is permitted. Cloove does not restrict a lawful industry because it sounds risky or because a foreign template lists it. A category earns restriction by presenting a risk we can actually articulate.

Cloove does not support any use of its products for:

Financial crime and fraud.

• Fraud of any kind, including advance-fee fraud, romance fraud, business email compromise, investment fraud and phishing.
• Money laundering, or handling the proceeds of crime.
• Terrorist financing, or support of a proscribed organisation.
• Proliferation financing.
• Any activity by or for a person or entity subject to applicable sanctions.
• Pyramid schemes, Ponzi schemes, matrix schemes, and multi-level structures whose returns come from recruitment rather than from a product.
• Purchase, sale or use of stolen financial instruments, account credentials, personal data or identity documents.
• Money mule activity, or receiving and forwarding funds for third parties without a lawful commercial reason.

Unlicensed regulated activity.

• Taking deposits, operating as a bank, issuing electronic money, operating a payment switch or providing payment services without the required licence.
• Unlicensed lending, insurance, securities dealing or collective investment schemes.
• Unlicensed foreign exchange dealing or bureau de change activity.
• Unlicensed lottery, betting or gaming operation.
• Offering guaranteed or unrealistic investment returns.

Illegal goods and activities.

• Narcotics and controlled substances, and the equipment and precursors used to produce them.
• Arms, ammunition, explosives, military and dual-use goods, and their components.
• Human trafficking, forced labour, exploitation, and any commercial sexual services involving coercion or a minor.
• Child sexual abuse material, in any form, without exception.
• Trade in protected wildlife, ivory and prohibited animal products.
• Stolen goods, counterfeit goods, pirated media and software, and goods that infringe a trade mark.
• Forged documents, fake identification, fake certificates and counterfeit currency.
• Violence for hire, threats and extortion.
• Hacking services, malware, ransomware, denial-of-service tools and other services whose purpose is unauthorised access.

Structural and conduct grounds.

• Shell entities with no genuine business activity, and structures established to obscure ownership or the origin of funds.
• A business that has materially misrepresented what it does, who owns it, or where its funds come from.
• A business that refuses to provide information Cloove reasonably requires.
• Any activity unlawful in Nigeria, or unlawful where the business operates or where its customers are.

These are lawful, and Cloove can support them. They require additional review before approval and operate on conditions such as evidence of a licence, tighter limits and closer monitoring.

Licensed gambling, betting, lottery and gaming

Evidence of a current licence, confirmation the provider will support the category, limits and closer monitoring.

Virtual asset activity

Exchanges, brokers, OTC desks and high-volume peer-to-peer trading. Subject to the applicable regulatory position, evidence of registration where required, source of funds information and senior sign-off. Cloove may decline the category.

Money transfer, remittance and foreign exchange businesses

Evidence of licence, clarity on whose funds move, senior sign-off.

Lending, BNPL, cooperatives, thrift societies, esusu and ajo collections

Evidence of licence or registration where required, clarity on the funds model, limits.

Investment advisory, asset management and fundraising

Evidence of registration where required, and review of promotional material.

Charities, religious organisations, NGOs and appeals

Registration evidence, information on funding sources and beneficiaries, and the purpose of collections.

Precious metals, gemstones, jewellery and high-value dealers

Business background, expected volumes, source of stock.

Cash-intensive businesses

Nightclubs, car washes, parking and some hospitality. Expected volume declaration, and monitoring against it.

Travel agencies and ticketing

Business background, delivery model and refund policy.

Adult content and adult services, where lawful

Provider confirmation, age verification controls, and checks on third-party payments. Cloove will decline where a provider will not support it.

Pharmaceuticals, supplements and medical devices

Pharmacy or dealer licence evidence and product category review.

Firearms retail where lawfully licensed

Licence evidence and senior sign-off. Cloove's default is to decline.

Debt collection

Business background and review of collection practices.

Ticket resale, event promotion and deposit-taking events

Delivery model, refund policy and limits.

Dropshipping and third-party fulfilment at scale

Supplier information, fulfilment model and delivery evidence.

Politically exposed persons and the businesses they control

Enhanced due diligence, source of funds, senior sign-off and a shorter review cycle.

Cross-border businesses with material activity in a high-risk jurisdiction

Enhanced due diligence and an understanding of the flows.

Some businesses will not fit cleanly into any of the above. Where a category is not listed and the risk is unclear, Cloove's compliance lead decides and records the decision and the reasoning, and the category is added to this framework at the next review if it is likely to recur. Decisions are made on what a business actually does, not on what it calls itself. This framework is reviewed at least annually, and whenever a provider changes its own list, a regulation changes, or a new pattern of misuse appears.

If you are not sure whether Cloove can support your business, ask before you onboard: compliance@clooveai.com. This framework forms part of the Terms of Service and sits alongside the AML / CFT / CPF Policy.