This Acceptable Use Policy (“Policy”) applies to all clients and prospective clients seeking to use the Company’s translation marketplace services. It sets out the categories of business activities that are not permitted to access or use the Company’s services and describes the procedures the Company applies to establish the lawful and legitimate nature of a client’s business. The Policy forms part of the Company’s internal compliance and risk management framework and is designed to ensure that no client activities create legal, financial, or reputational exposure.
While the Company is not a regulated entity under United Kingdom financial services law, it observes relevant legal standards and good industry practice, including guidance derived from United Kingdom legislation and applicable international frameworks, in order to safeguard its operations and maintain the confidence of financial institutions and business partners. The purpose of this Policy is to define the industries and activities that the Company will not cooperate under any circumstances, to explain the internal verification measures undertaken to confirm the nature and legitimacy of a client’s business, and to affirm the Company’s right to refuse or terminate services where prohibited activities, misrepresentations, or other unacceptable risks are identified.
For the purposes of this Acceptable Use Policy:
“Company” means the translation marketplace operated under the legal entity registered in the United Kingdom and subject to applicable UK laws.
“Client” refers to any legal entity or individual applying to use or currently using the Company’s services for the purpose of placing, managing, or receiving translation or related linguistic services.
“Prohibited Business Activities” means any industry, sector, or activity listed under this Policy which the Company will not cooperate or continue to service, irrespective of jurisdiction.
“Verification of Business Nature” means the process of collecting, reviewing, and assessing corporate documents, ownership and control information, business model descriptions, public records, sanctions and watchlist screening results, and other reliable sources to confirm the lawful purpose and economic substance of the Client’s operations.
“Applicable Laws” refers to relevant United Kingdom legislation and publicly available international frameworks that the Company takes into account for compliance and risk management purposes, including the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Sanctions and Anti-Money Laundering Act 2018, the Modern Slavery Act 2015, and the Fraud Act 2006, as well as guidance issued by competent authorities such as HM Treasury and the Office of Financial Sanctions Implementation.
“Sanctions” refers to prohibitions and restrictions arising from designations issued under UK law or other applicable international regimes, including restrictions on dealings with designated persons or entities that are owned or controlled by them.
This Policy takes into account relevant legal and regulatory standards in the United Kingdom and reflects good practice expected by financial institutions and business partners. Although the Company is not itself a regulated entity under United Kingdom financial services law, it recognises the importance of aligning its risk controls with key statutory provisions. The Proceeds of Crime Act 2002 defines offences related to money laundering and establishes the principle that businesses must not facilitate the use of criminal property. The Terrorism Act 2000 prohibits the provision of support or services connected to terrorist financing and terrorist organisations.
The Sanctions and Anti-Money Laundering Act 2018 enables the implementation of international sanctions regimes and prohibits dealings with designated persons, entities, and jurisdictions. The Modern Slavery Act 2015 criminalises forced labour, human trafficking, and other forms of human exploitation. The Fraud Act 2006 establishes liability for misrepresentation, abuse of position, and dishonest conduct in commercial dealings. The Company also considers guidance issued by HM Treasury and the Office of Financial Sanctions Implementation, as well as relevant international conventions and sanctions frameworks. This legal and regulatory context informs the Company’s exclusion of prohibited business categories and the procedures used to confirm the lawful nature of a client’s activities.
The Company does not provide services to clients engaged in certain categories of activities that present unacceptable legal, regulatory, or reputational risks. These include:
businesses involved in the sale or distribution of controlled substances;
the sale of firearms, ammunition, explosives, or related accessories;
any form of human exploitation including escort services, illegal labour, or trafficking;
fraudulent investment schemes including multi-level marketing structures operating as pyramid schemes or other get-rich-quick schemes;
marketplaces or enterprises engaged in the sale of counterfeit luxury products, pirated software, or stolen goods;
organisations promoting hate speech, extremist ideologies, or terrorism;
operations linked to illegal activities on the dark web including hacking tools or illicit marketplaces;
entities facilitating tax evasion, identity theft, or fraudulent financial transactions;
businesses operating in or dealing with jurisdictions subject to international sanctions including but not limited to North Korea, Iran, and Russia;
any activities involving child pornography, revenge pornography, non-consensual sexual content, or highly regulated adult services;
entities used as shell companies without genuine business operations where there is a risk of money laundering or financial crime.
Engagement in any of these sectors is strictly prohibited, and potential cooperation with clients involved in such activities will be rejected without exception.
The Company carries out a basic verification of each client’s business to confirm that the activities are lawful and consistent with the representations made. As part of this process the client is asked to describe the nature of its business and, where available, to provide a website or other public source showing its operations. The Company checks that the legal entity name provided matches the information available on the website or in open sources. Where no website exists, the Company may request a simple document confirming the legal entity name in order to establish that the business has a genuine basis. These steps are proportionate to the low-risk nature of the Company’s services and are intended solely to ensure that the business has a legitimate purpose. If the client fails to provide sufficient clarity regarding its activities or its legal entity name, the Company may refuse to proceed or may terminate the relationship.
The Company reserves the right to refuse the cooperation with any client whose business falls within the prohibited categories set out in this Policy or whose activities cannot be verified as lawful and legitimate. The Company may suspend or terminate an existing relationship if it becomes aware of misrepresentation, non-disclosure, or subsequent involvement in prohibited activities, even if such involvement was not apparent at the time of business cooperation. Termination or suspension may also occur where information provided by the client is false, misleading, or incomplete, or where the client fails to provide additional documentation or clarification when reasonably requested. The Company may report relevant matters to competent authorities where required by law or where there is suspicion of unlawful activity, and such reports may be made without prior notice to the client. The Company accepts no liability for losses suffered as a result of refusal, suspension, or termination of services under this Policy, and its decision in these matters shall be final.
The Company maintains records of all documents, information, and assessments collected during the verification of a client’s business nature and the application of this Policy. Such records are retained for a minimum period of five years as a matter of good practice, even though the Company is not a regulated entity under United Kingdom financial services legislation. Records are stored securely and must be accessible without undue delay for the purpose of internal review or upon request by business partners or competent authorities. The Company periodically reviews this Policy and its implementation to ensure that the controls remain appropriate to the nature of its activities and risk profile. Reviews are conducted internally under the oversight of senior management, and any deficiencies identified are documented and remediated promptly.