Prohibited Activities

Any corporates or individuals directly or indirectly involved in the below:

1. Illegal Drugs & Drug Paraphernalia

• Illegal drugs

• Substances designed to mimic illegal drugs

• Equipment designed for making or using drugs

2. Fraudulent Identification

• Fake references or ID-providing services

3. Telecommunications Abuse

• Jamming devices

• Other equipment designed to manipulate or disrupt telecommunications

4. Unlawful Violence

Any business or organization that:

• Engages in, encourages, promotes, or celebrates unlawful violence or physical harm to persons or property

• Targets violence toward any group based on race, religion, disability, gender, sexual orientation, national origin, or other immutable characteristic

5. Unlawful Products & Services

• Any product or service that violates applicable laws in the jurisdictions where it is offered or targeted

6. Intellectual Property Infringement

• Unauthorized sale or distribution of music, movies, software, or other licensed materials

• Counterfeit goods; illegally imported or exported products

• Unauthorized sale of brand-name or designer items

• Any other service or product that infringes trademarks, patents, copyrights, trade secrets, or privacy rights

7. Unfair, Predatory, or Deceptive Practices

• Pyramid schemes

• “Get rich quick” schemes, including:

  • Promises of high rewards with little effort or upfront work

  • Outrageous claims, deceptive or fake testimonials

  • High-pressure upselling or inducements without follow-through

• No-value-added services (resale of services without added benefit; unauthorized resale of government offerings)

• Predatory sales of online traffic or engagement

• Negative-response marketing and telemarketing

• Predatory mortgage consulting, lending, credit repair, and counseling

• Predatory investment opportunities with no or low money down

• Remote technical support scams; mugshot publication/pay-to-remove sites; essay mills; chain letters; door-to-door sales

• Any other business Delos deems unfair, deceptive, or predatory

8. Adult Content & Services

• Pornography or mature content (literature, imagery, media) depicting explicit acts

• Prostitution, escorts, pay-per-view sexual services, sexual massages, adult live chats

• Adult video stores; gentlemen’s clubs, topless bars, strip clubs

• Online dating services

9. Certain Legal Services

• Law firms collecting fees for non-legal service purposes (high AML risk)

• Bankruptcy attorneys

• Bail bond services

10. Firearms, Explosives & Dangerous Materials

• Dual-use goods

• Firearms, ammunition, gunpowder, weapons, fireworks, other explosives

• Peptides, research chemicals, toxic, flammable, or radioactive materials

• Direct sales of precious metals (evaluated case-by-case)

11. Unlicensed Gambling & Cash-Intensive Businesses

• Unlicensed or unauthorized games of chance (including online gambling, sweepstakes, contests, fantasy sports for prize)

• Sports forecasting or odds-making for prize

• Lotteries (national lotteries evaluated case-by-case)

• Bidding-fee auctions

• Other cash-intensive operations

12. Cannabis & Marijuana

• Cannabis products (including dispensaries and related businesses)

13. Sanctions & Licensing Violations

• Unlicensed or unregistered financial institutions or payment service providers

• Entities or individuals subject to U.S. or other applicable sanctions

• Customers or beneficial owners holding ≥ 50% interest who are sanctioned

• Shell banks or shell companies; companies formed by bearer shares (unless publicly traded on a recognized exchange)