13. Fees and Charges

13.1  Our fees and charges for the Services are set out in our Fee Schedule, available at https://www.bloomsburymoney.com/fees. The Fee Schedule forms part of the Agreement.

13.2  Fees may be agreed with you on a case-by-case basis and confirmed in writing upon completion of onboarding. The fees applicable to you are determined by reference to a range of factors including, without limitation, your jurisdiction, risk profile, payment frequency and the requirements of ongoing transaction monitoring. In the absence of bespoke fees agreed in writing, the standard fees published in the Fee Schedule apply.

13.3  Fees may change from time to time. The most recent Fee Schedule is always the version published at https://www.bloomsburymoney.com/fees, and it is your responsibility to review it periodically. For material fee changes we will, where reasonably practicable, give you advance notice in accordance with Section 24; your continued use of the Services after a change takes effect constitutes acceptance of the revised fees.

13.4  In addition to our fees, third-party charges (including Correspondent Bank charges, intermediary bank deductions, blockchain network fees, ATM operator fees and scheme fees) may apply and may be deducted from payment amounts or debited to your Account.

13.5  We may deduct fees, charges, taxes and any amounts you owe us directly from your Account, and we may exercise a right of set-off against any balance you hold with us.

14. Financial Crime, Fraud Prevention and AML/CFT

14.1  We are committed to the prevention of money laundering, terrorist financing, proliferation financing, fraud, bribery, corruption, tax evasion facilitation and sanctions evasion, and we maintain systems and controls required by the AML/CFT Legislation and the JFSC.

14.2  You warrant, on a continuing basis, that: (a) all funds and Virtual Assets introduced to your Account derive from legitimate sources; (b) you are not, and no beneficial owner, controller, Authorised User or Authorised Cardholder of yours is, subject to sanctions administered by Jersey, the United Nations, the United Kingdom, the European Union, the United States (OFAC) or any other relevant authority; (c) you will not use the Services for any unlawful purpose; and (d) all information you provide to us is true, accurate and complete.

14.3  We may at any time, and without liability: (a) request additional information or documentation and suspend Services pending its receipt; (b) delay, block, freeze, return or refuse any transaction or instruction; (c) freeze or suspend your Account; (d) file reports with the Jersey Financial Intelligence Unit and other authorities; and (e) take any other action we consider necessary to comply with the AML/CFT Legislation or to protect ourselves, our Correspondent Banks or other clients from fraud, dishonesty or financial crime.

14.4  Tipping-off. Where we take action under this Section, we may be prohibited by law from informing you of the action, the reasons for it, or the existence of any report or investigation, and you agree that we will have no liability for any loss arising from such action or from our compliance with legal obligations.

14.5  Fraud disclaimer. We employ monitoring and controls to detect fraud, but we do not guarantee that fraud will be prevented or detected. To the maximum extent permitted by Jersey law, we are not liable for losses arising from fraud, dishonesty, social engineering, authorised push payment fraud, invoice redirection fraud or similar schemes perpetrated by third parties, or where you or your Authorised Users have acted fraudulently, dishonestly, with gross negligence or in breach of these Terms. You must satisfy yourself as to the identity and legitimacy of any payee before instructing a payment; payments you authorise to a fraudster are treated as authorised payments.

14.6  You must cooperate fully with any investigation by us, our Correspondent Banks or any competent authority, and you must notify us immediately if you become aware of any fraud, error or suspicious activity affecting your Account.

15. Account Reviews, Suspension and Closure

15.1  Periodic reviews. All Accounts are subject to periodic review by us, including reviews of your DD Information, risk profile, activity patterns and continued eligibility for the Services. You must respond promptly to review requests; failure to do so may result in suspension or closure of your Account.

15.2  Right to close without detail. We reserve the right to suspend, restrict or close your Account, and to terminate any or all Services, at any time, without providing any reason or detail, where permitted by Applicable Laws. Where we close your Account other than in the circumstances described in clause 15.3, we will where practicable give you reasonable prior notice.

15.3  We may suspend or close your Account and terminate the Agreement with immediate effect and without notice where: (a) we are required to do so by law, a regulator, a court, Visa or a Correspondent Bank; (b) we know or suspect fraud, financial crime or sanctions exposure; (c) you materially breach these Terms or provide false or misleading information; (d) you become insolvent or subject to analogous proceedings; or (e) continuing the relationship would, in our reasonable opinion, expose us to legal, regulatory or reputational risk.

15.4  You may close your Account at any time by taking the steps set out on the Platform or by giving us notice through the channels we specify, subject to settlement of outstanding transactions (including unsettled FX Conversions and Card transactions) and amounts owed.

15.5  On closure, and subject to Applicable Laws and the completion of our checks, we will return any remaining balance to an account or wallet in your own name, less any amounts you owe us. We may withhold funds or Virtual Assets where required by law, a competent authority, a Correspondent Bank, or an ongoing investigation, for as long as necessary.

16. Prohibited Activities

16.1  You must not use the Services, and must ensure your Authorised Users and Authorised Cardholders do not use the Services: (a) for any unlawful purpose, including money laundering, terrorist financing, fraud, tax evasion or sanctions evasion; (b) in connection with any business or activity we have notified you is prohibited or restricted under our risk appetite (which may include, without limitation, unlicensed money transmission, unlicensed gambling, adult content, weapons, narcotics, counterfeit goods, dark-web marketplaces, mixers/tumblers, and shell banks); (c) on behalf of undisclosed third parties; (d) to abuse, exploit or circumvent limits, controls or scheme rules; or (e) in any manner that may damage our reputation or our relationships with Correspondent Banks or Visa.

16.2  Breach of this Section entitles us to suspend or terminate the Services immediately and to report the matter to relevant authorities.

17. Security and Your Obligations

17.1  You must maintain appropriate security over the devices, systems, Security Credentials and email accounts used to access the Services, keep your contact and DD Information up to date, and implement reasonable internal controls over Authorised Users.

17.2  You must notify us immediately of any actual or suspected unauthorised access, compromise of Security Credentials, or security incident affecting your use of the Services. We may suspend access to protect you or us while any incident is investigated.