PayPal Alternative Payment Methods Agreement

APMs

Wallet

Alipay is a digital wallet that can be used by all Customers registered as a member with Alipay.

You will ensure that Alipay Services will not be used for:

1. Illegal political audio-visual products and publications, illegal reactionary cards and program channels, state secret documentations and information, other reactionary articles and speeches.
2. Gambling tools, private lottery, gambling services, lottery tickets, pyramid selling, gold futures, lucky draw, high-risk services.
3. Drug-taking tools, ammunitions and weapons/firearms and accessories, controlled instruments, crime articles, fireworks and firecrackers, poisonous articles and hazardous chemicals, adult drugs (e.g., aphrodisiacs).
4. Credit speculation services (including speculation of Taobao credit rating), credit card cashing services, crowd funding websites, counterfeit currency, bank account Transaction (bank cards), stock, fund, insurance, insurance platform, periodical investment in gold, bank financial products, cashback services, single-purpose prepaid cards, securities, illegal fund-raising, foreign exchange services, virtual currency in foreign accounts, receipts (invoices), Bitcoin, Litecoin, YBcoin and other virtual currency, Transactions, MCard etc., Auction, Pawn, Payment institutions, circulating RMB, foreign currencies.
5. Fetal gender diagnosis, Human organs, Surrogacy services, examination services, medical devices, contact lenses.
6. Hacking-related, malware, other software services which jeopardize Alibaba and the subsidiaries of Alibaba, video chatting services, religious websites, online cemetery and worshipping and other services, computer privacy information monitoring, satellite antenna etc., spying instruments, other personal privacy-harming articles or services, ID card information and other information which infringe other’s privacy, certificate issuing and stamp carving.
7. Foreign-related matchmaking services, items and services in violation of relevant state regulations, poor quality (fake) food, tobacco, crude oil, charities, smuggled articles, special provisions for specific periods of time (e.g. the Olympic Games), cultural relics, luxury goods, auto sales and rental services.

Apple Pay Web

Payment Type

Apple Pay Wallet

Chargeback Risk

Yes

Payment Guarantee

Yes (as per the credit card processing guidelines)

Refund possibility

Yes

Transaction minimum

N/A

Transaction maximum

N/A

Specific Prohibited Goods and Services

Please see the list of Prohibited Goods and Services found in the Apple Pay Web terms at https://developer.apple.com/terms/apple-pay-web/

Supplemental Terms

Please see additional terms applicable to your integration of APM functionality into your online checkout/platform at https://developer.apple.com/terms/apple-pay-web/

Bancontact

Payment Type

Debit Card

Bancontact is a debit card Payment Method, whereby a debit card is issued by an authorised credit institution, which allows customers to directly pay for goods and services from their bank accounts.

Chargeback Risk

No

Payment Guarantee

No

Refund possibility

Yes

Transaction minimum

€1.00 per transaction

Transaction maximum

N/A

Specific Prohibited Goods and Services

None other than those prohibited goods and services set out within the User Agreement

Supplemental Terms

N/A

Bancomat Pay

Payment Type

Real-time Bank Transfer

Chargeback Risk

Yes

Payment Guarantee

No

Refund Possibility

Yes

Transaction Minimum

€1.00 per transaction

Transaction Maximum

No limit, depending on issuing bank agreement on the max limit amount with the customer/p>

Specific Prohibited Goods and Services

None other than those prohibited goods and services set out within the User Agreement

Supplemental Terms

1. Bancomat Pay is limited to customers in Italy, the Vatican State and San Marino.
2. You shall ensure that Bancomat Pay’s trademark is displayed and used only in accordance with the applicable requirements set out in the Bancomat Pay Regulation for the Use of Trademarks: https://bancomat.it/it/bancomat/brandbook-guidelines
3. You shall provide the Customer before confirming the payment with:

i) the precise description of the service or the goods purchased;

ii) the total amount of the payment;

iii) a receipt (paper or electronic) bearing the details of the payment.

BLIK

Payment Type

Real-time Bank Transfer

BLIK is a bank transfer payment method. Recipients can receive a real time confirmation of the transaction.

Chargeback Risk

No

Payment Guarantee

No

Refund Possibility

Yes

Transaction Minimum

PLN 0.01 per Transaction

Transaction Maximum

PLN 10,000.00 per Transaction

Specific Prohibited Goods and Services

None other than those prohibited goods and services set out within the User Agreement

Supplemental Terms

You must prominently display, on your website or device as applicable, the BLIK name or Trademarks in a manner consistent with the BLIK Brand Book.

EPS

Payment Type

Real-time Bank Transfer

EPS is a bank transfer payment method. Recipients can receive a real time confirmation of the transaction. EPS is facilitated by EPS participating banks.

Chargeback Risk

No

Payment Guarantee

Yes - Payment Guarantee shall mean every transaction that is flagged as complete or successful (whichever is applicable) will be paid to your Account and the funds cannot be revoked, subject further to these terms and the User Agreement and your compliance with them.

Refund possibility

Yes

Transaction minimum

€1.00 per transaction

Transaction maximum

N/A

Specific Prohibited Goods and Services

None other than those prohibited goods and services set out within the User Agreement

Supplemental Terms

You shall report any events that require reliance on the EPS Payment Guarantee to PayPal without delay.

Finnish (Verkkopankki)

Payment Type

Real-time Bank Transfer

Finnish Online Bank Transfer is a bank transfer Payment Method.

Recipients can receive real time confirmation of the transaction.

Chargeback Risk

No

Payment Guarantee

No

Refund possibility

Yes

Transaction minimum

EUR 0.65 per transaction

Transaction maximum

EUR 20,000.00 per Transaction

Specific Prohibited Goods and Services

In addition to those prohibited goods and services listed in the Agreement: illegal gambling; prostitution; counterfeit goods; product piracy; illegal sale or distribution of tobacco products or pornography or the depiction of severe violent acts; Nordea Bank does not allow loading of wallets or prepaid products

Supplemental Terms

1. You shall provide all necessary data in compliance with specifications provided by PayPal. Failure to comply with the specifications for data delivery may result in a delay, suspension or cancellation of processing of effected sales.

2. You shall compensate PayPal for reasonable expenses incurred upon a dispute arising with regard to a Transaction should PayPal actively be involved in mediation or other similar proceedings between a Customer and You.

3. The maximum limit of the liability is the invoiced amount of the sale (sale of products or services by You to the Customer) to which the damages directly relate to or 1000 EUR depending on which amount is lower. However, the total aggregate liability may not exceed 5000 EUR. These limitations do not apply if the damages have been caused by willful action or gross negligence.

Giropay

Payment Type

Real-time Bank Transfer

Giropay is a bank transfer payment method. Recipients can receive a real time confirmation of the transaction.

Chargeback Risk

No

Payment Guarantee

Yes - Payment Guarantee shall mean every transaction that is flagged as complete or successful (whichever is applicable) will be paid to your Account and the funds cannot be revoked, subject further to these terms and the User Agreement and your compliance with them.

Refund possibility

Yes

Transaction minimum

€1.00 per transaction

Transaction maximum

N/A

Specific Prohibited Goods and Services

In addition to any prohibited goods or services set out within the User Agreement:

Payment instruments (cash, savings or e-money, currencies including virtual currencies such as bitcoins, as well as checks) as far as the recipient of the payment instrument can’t be identified by you, except vouchers or stored value products.

Supplemental Terms

1. Giropay is restricted to customers with access to an online banking compatible account held at an authorised credit institution based in Germany. PayPal does not guarantee that all German bank accounts are giropay compatible.
2. You must adhere to all terms and conditions of the giropay Rules and Regulations including the use of the giropay logo which is limited to the European region.
3. In using giropay as the payment method, you shall not request for any customers data, in particular personal data such as IBAN or names.
4. The giropay Payment Guarantee is limited to EUR10,000 per transaction.
5. You shall report any events that require reliance on the giropay Payment Guarantee to PayPal without delay.
6. The giropay Payment Guarantee expires 6 weeks after a receipt of the given transaction flagged as complete or successful, whichever is applicable unless you have reported the claim in writing before the expiry of the 6 week period.

iDEAL

Payment Type

Real-time Bank Transfer

iDEAL is a bank transfer payment method. Recipients can receive a real time confirmation of the transaction. iDEAL is restricted to use by customers who have been issued an online bank account that is iDEAL compatible and held at a bank based in the Netherlands.

Chargeback Risk

No

Payment Guarantee

Yes - Payment Guarantee means every transaction that is flagged as complete or successful (whichever is applicable) will be paid to your Account and the funds cannot be revoked, subject further to these terms and the User Agreement and your compliance with them.

Refund possibility

Yes

Transaction minimum

N/A

Transaction maximum

N/A

Specific Prohibited Goods and Services

None other than those prohibited goods and services set out within the User Agreement

Supplemental Terms

1. You must make the information about the complaints procedure easily available to customers on your website.
2. You are not permitted to offer the iDEAL Payment Method via e-mail link services unless you obtain the prior written permission of PayPal. An iDEAL payment link is a URL that leads to your payment page on which a customer can initiate an iDEAL transaction.
3. You must cooperate with requests for information in specific situations that require further investigation in relation to the iDEAL payment method as may be notified to PayPal or you from time to time.
4. The iDEAL Merchant Integration Guide can be accessed here: https://betaalvereniging.atlassian.net/wiki/spaces/IPD/overview; you must adhere to the terms and conditions for the use of iDEAL, including the use of the iDEAL logo, as described at www.ideal.nl/en/payee/logos-banners/.
5. You shall report any events that require reliance on the iDEAL Payment Guarantee to PayPal without delay.
6. Where at PayPal’s sole discretion you are deemed to be high risk, PayPal reserves the right to request you to implement a Customer registration process to record at least the following data concerning the Customer:

a) Name and e-mail address;

b) Account number and name for the bank account number which is being used to make purchases via the iDEAL Payment Method;

c) Additional information for verification in step 2 and the monitoring of Transactions, for example:

i. IP address

ii. Browser fingerprint

iii. Mobile number

MB Way

Payment Type

Wallet

MB Way is a Payment Method restricted to customers in Portugal. MB Way is made available by the association of a card with one or more aliases (mobile phone number, e-mail address, or others that may be deemed appropriate by PayPal).

Chargeback Risk

No

Payment Guarantee

No

Refund Possibility

Yes

Transaction Minimum

N/A

Transaction Maximum

Depends on the bank and user limit

Specific Prohibited Goods and Services

None other than those prohibited goods and services set out within the User Agreement

Supplemental Terms

N/A

Mercado Pago 

Payment Type 

Mercado Pago is an online payments provider that allows buyers in Brazil and Mexico to make payments using credit cards, debit cards, prepaid cards, Mercado Pago wallet balance, and other payment methods. 

Chargeback Risk 

Yes 

Payment Guarantee 

Yes - Payment Guarantee shall mean every transaction that is flagged as complete or successful (whichever is applicable) will be paid to your Account and the funds cannot be revoked, subject further to these terms and the User Agreement and your compliance with them. 

Refund Possibility 

Yes 

Transaction Minimum 

MXN 0.01 per Transaction 

BRL 0.01 per Transaction 

Transaction Maximum 

MXN 1,000,000.00 per Transaction 

BRL 10,000,000.00 per Transaction 

Specific Prohibited Goods and Services 

For Mexico:  

In addition to any prohibited goods or services set out within the User Agreement: goods and services prohibited under Mercado Pago Terms and Conditions, as well as the following: prescription medicines, pharmaceutical products, dietary supplements not permitted for sale, gambling of any kind, financial products and services not approved by competent financial supervision authorities, malware (e.g., rogueware, viruses, etc.), funding of political parties or activities, direct marketing, postal number operations, bank drafts and postal wires, wholesale clubs, multilevel pyramid selling, timeshares, collection agencies, factoring companies, liquidators, bail bond companies, bankruptcy lawyers, financial advisors, share titles, investment trust funds, investments funds, currency exchange, payment orders from non-financial institutions, guarantee and money exchange offices, traveler's checks, travel-related services and cruise lines (excluding travel agencies), coin collections, stamps, coin shops, philately, Airtran Airways, Airtran Air, check cashing, automatic payments and subscriptions, employment agencies, and cash advance or credits. 

For Brazil:  

In addition to any prohibited goods or services set out within the User Agreement: services are prohibited.  

Some goods are prohibited by Mercado Pago under its Terms and Conditions. For a full list of the prohibited goods and services, please visit: https://www.mercadopago.com.br/ajuda/3264 

Supplemental Terms 

For Mexico: Mercado Pago payment services will be subject to Mercado Pago Terms and Conditions for Mexico.  

For Brazil: Mercado Pago payment services will be subject to Mercado Pago Terms and Conditions for Brazil.  

For Brazil and Mexico: 

You are not permitted to use Mercado Pago´s brand, logo, commercial name, and additional intellectual property rights other than to list Mercado Pago as a payment method. If you attempt to use Mercado Pago´s intellectual property rights in an unauthorised manner, we reserve the right to revoke our services. 

Mercado Pago is not liable for any additional charges due to your failure to submit correct bank details. 

The user cannot resell payment management services to third parties. 

Multibanco

Payment Type

Real-time Bank Transfer

Multibanco is a Payment Method restricted to customers in Portugal offering two alternatives for payments: One alternative is a bank transfer via the customer ́s online banking portal, the other alternative is cash payment at the ATM s of various Portuguese bank branches.

Chargeback Risk

No

Payment Guarantee

No

Refund Possibility

N/A

Transaction Minimum

N/A

Transaction Maximum

EUR 99,999.99 per Transaction

Specific Prohibited Goods and Services

None other than those prohibited goods and services set out within the User Agreement

Supplemental Terms

N/A

MyBank

Payment Type

Real-time Bank Transfer

MyBank is a bank transfer Payment Method. Recipients can receive a real time confirmation of the transaction.

Chargeback Risk

No

Payment Guarantee

No

Refund possibility

Yes

Transaction minimum

N/A

Transaction maximum

N/A

Specific Prohibited Goods and Services

For the avoidance of doubt and in addition to any prohibited goods or services set out within the User Agreement: Activities which could be punishable as endangerment of minors, paedophilia, pornography, for infringement of works protected by intellectual property rights and means of payment, the non-compliance with the protection of personal data, with systems automated data processing, acts of money laundering, non-compliance relating to gambling and betting, horse racing, lotteries and provisions relating to conditions of exercise of regulated professions.

Supplemental Terms

You are not permitted to use My Bank Logo and additional intellectual property rights other than as permitted for these alternative payment methods services. For any further use please comply with MyBank Style Guide for Businesses found at the following website https://www.mybank.eu/mybank/mybank-style-guidelines-for-merchant-websites/. If you attempt to use the MyBank Logo in an unauthorised manner, in a manner that is not intended or allowed, or in significant contravention of these requirements, we reserve the right to revoke our services.

PayU

Payment Type

Real-time Bank Transfer

PayU is a bank transfer Payment Method. Recipients can receive a real time confirmation of the transaction.

Chargeback Risk

No

Payment Guarantee

No

Refund possibility

Yes

Transaction minimum

PLN 0.01/Tx; CZK 0.01/Tx

Transaction maximum

N/A

Specific Prohibited Goods and Services

In addition to those prohibited goods and services listed in the Agreement: Prescription medicines, pharmaceutical products and dietary supplements not permitted for sale; drugs, intoxicants, including designer drugs, as well as equipment and technology used for their farming, production, trade, etc.; gambling without legal authority; weapons, ammunition and gas launchers; online services with pornographic content, e.g. chat rooms, video cameras, VOD movies; financial products and services if offered as part of an activity not supervised by competent financial supervision authorities; malware, e.g. rogueware, viruses, etc.; political parties and related websites used to support them or collect funds for political activities; crowdfunding; intermediaries accepting payments on behalf of many recipients without legal authority or not meeting the requirements of card associations/intermediate bodies

Supplemental Terms

1. You shall ensure that the Customer is informed in clearly recognizable and easily accessible form that transactions made via the PayU Payment Method are irrevocable.

2. PayPal and PayU are not liable for any additional charges due to incorrect bank details if you have not ensured that only correct bank details are submitted.

3. Merchants using the PayU Payment Method are liable for all unauthorised or fraudulent Transactions made with the Payment Method.

4. You shall ensure that:

a) any Customer identification and/or authenticating data that could be used to place orders shall not be stored electronically or written down in another form;

b) during the input of Customer identification and/or authenticating data that could be used to place orders, third parties are prevented from obtaining such data.

Disclosure of Customer identification and/or authenticating data to third parties is strictly prohibited.

POLi

Payment Type

Real-time Bank Transfer

POLi is a bank transfer payment method. Recipients can receive a real time confirmation of the transaction. POLi is restricted to customers holding accounts with banking institutions in Australia and New Zealand. PayPal does not guarantee that all New Zealand or Australian bank accounts are POLi compatible.

Chargeback Risk

No

Payment Guarantee

No

Refund Possibility

No

Transaction Minimum

AUD/NZD 1.00 per Transaction

Transaction Maximum

AUD/NZD 10,000.00 per Transaction

Specific Prohibited Goods and Services

In addition to any prohibited goods or services set out within the User Agreement: gambling.

Supplemental Terms

N/A

Przelewy24 (P24)

Payment Type

Real-time Bank Transfer

Przelewy24 is a bank transfer Payment Method. Recipients can receive a real time confirmation of the transaction.

Chargeback Risk

No

Payment Guarantee

No

Refund possibility

Yes

Transaction minimum

PLN 0.05 per transaction

Transaction maximum

N/A

Specific Prohibited Goods and Services

None other than those prohibited goods and services set out within the User Agreement

Supplemental Terms

Every transaction is associated with a unique transaction number and other details (the “Transaction Details“) in order to facilitate enquiries or potential complaints. You shall save the Transaction Details in a secure manner. Any complaints pertaining to incorrectly executed transactions shall be submitted directly to PayPal who will thereafter forward the matter to Pzrelewy24 Payment Scheme for investigation. In relation to such complaints, you must provide the following details:

a) E-mail address;

b) Transaction number;

c) Transaction amount;

d) Full name of the holder of the originating bank account from which the Transaction amount was to be

transferred;

e) Name of the bank that holds the account from which the transaction amount was to be transferred or to

which the transaction was transferred to as applicable;

f) Transaction date; and

g) In the case of payment from a card: the name of the card;

h) In the case of an SMS payment: the Customer’s mobile telephone number.

4. Notwithstanding the foregoing, any complaints pertaining to transactions made 90 or more days prior to such

complaint may be refused for review by the Przelewy24 Payment Scheme.

Safetypay

Payment Type

Real-time Bank Transfer

Safetypay is a bank transfer payment method. Recipients can receive a real time confirmation of the transaction.

Chargeback Risk

No

Payment Guarantee

Yes

Refund possibility

Yes

Transaction minimum

N/A

Transaction maximum

15000 EUR

Specific Prohibited Goods and Services

In addition to any prohibited goods or services listed above, You shall not use Safetypay to accept payment for, make payment to, or, directly or indirectly, facilitate: Bootleg recordings; counterfeit items; embargoed goods; illegal drugs and paraphernalia; offensive, racially or culturally insensitive material; adult content, materials, and/or services, including, but not limited to adult books and videos, adult telephone conversations, adult websites, companion/ escort services, dating services (sexually oriented), mail order brides, miscellaneous adult entertainment; cash; damages, losses, penalties, or fines of any kind; costs or fees over the normal price of Merchants’ goods or services (applicable taxes) or charges that Customers have not specifically approved; overdue amounts, or amounts covering returned or stop-payment checks; sales made by third parties; amounts that do not represent bona fide sales of goods and services by Merchant’s business (e.g., purchases by Merchant’s owners (or their family members) or employees); illegal business Transaction; money laundering or the financing of terrorist activities.

Supplemental Terms

N/A

Satispay

Payment Type

Wallet

Satispay provides a bank account enabled mobile payment platform.

Chargeback Risk

No

Payment Guarantee

Yes

Refund possibility

Yes

Transaction minimum

EUR 0.01

Transaction maximum

N/A

Specific Prohibited Goods and Services

In addition to those prohibited goods and services listed above, You shall not use Satispay to accept payment for, make payment to, or, directly or indirectly, facilitate:

a)  Telecommunication services, including local and long distance calls, credit card calls, calls through use of magnetic stripe reading telephones and faxes;

b)  Money Orders - Wire Transfer;

c)  Pawn shops;

d)  Outbound telemarketing;

e)  Inbound telemarketing;

f)  Ticket Agencies (Radio, television and other direct Marketers not elsewhere classified);

g)  Financial institutions — manual cash disbursements;

h)  Financial institutions — automated cash disbursements;

i)  Loan Payments, Institution;

j)  Non-financial institutions — foreign currency, money orders (not wire transfer), scrip and travelers’ checks;

k)  Dealers—Securities, Mutual Funds, Stocks, Commodities, Bonds;

l)  Timeshares;

m)  Dating and escort services;

n)  Buying and shopping services and clubs;

o)  Consumer credit reporting agencies;

p)  Employment agencies and temporary help services;

q)  Betting (including Lottery Tickets, Casino Gaming Chips, Off-Track Betting and Wagers).

Supplemental Terms

Merchants acknowledge and agree, that personal data will be transferred to Satispay for processing of transactions. Such personal data will be processed by Satispay in accordance with its privacy notice, which can be found at: https://static-www-satispay-com.s3.amazonaws.com/privacy/Payment-Scheme/Satispay-Payment- Scheme_Privacy-en.pdf

SOFORT

Payment Type

Real-time Bank Transfer

SOFORT Banking/SOFORT Überweisung is a bank transfer Payment Method. Recipients can receive a real time confirmation of the transaction.

Chargeback Risk

No

Payment Guarantee

No

Refund possibility

Yes

Transaction minimum

€1.00 per transaction

Transaction maximum

N/A

Specific Prohibited Goods and Services

None other than those prohibited goods and services set out within the User Agreement

Supplemental Terms

N/A

Trustly

Payment Type

Real-time bank transfer

Chargeback Risk

No (once the money is settled in the Merchant account)

Payment Guarantee

No

Refund possibility

Yes

Transaction minimum

EUR 0.01 per transaction. (Subject to conditions imposed by Customer’s bank)

Transaction maximum

Subject to conditions imposed by Customer’s bank

Specific Prohibited Goods and Services

In addition to those prohibited goods and services listed in the Agreement: Bitcoin

Supplemental Terms

(1) You shall ensure that Trustly’s logotype(s) and trademark(s) are exposed and presented in an appealing and appropriate manner, and in accordance with the applicable service presentation requirements as set out at: https://trustly.com/en/developer/documents.

(2) You acknowledge and agree that: (a) The Trustly service is dependent on the functionality of third-party systems, primarily banks, and Trustly does not guarantee the functionality of its service in the event of any failure, malfunction, or adjustment within, or associated with, such third-party systems; (b) Transaction speeds may be adversely impacted at those times when transaction volumes spike or peak significantly, or during the planned maintenance of the Trustly service; and (c) PayPal and Trustly are not liable for any loss or damage due to any degradation of the functionality of third-party systems as described in sub-section (a) herein, or during significant peaks of transaction volumes or the planned maintenance of the Trustly service as described in sub-section (b) herein.

Trustpay

Payment Type

Real-time Bank Transfer

Trustpay is a bank transfer payment method. Recipients can receive a real time confirmation of the transaction.

Chargeback Risk

No

Payment Guarantee

No

Refund Possibility

N/A

Transaction Minimum

EUR 0.01 per transaction

Transaction Maximum

N/A

Specific Prohibited Goods and Services

In addition to any prohibited goods or services set out within the User Agreement: Weapons or related items (e.g., guns, gun parts, ammunition, knives), financial products resembling a Ponzi scheme, illegal drugs and drug paraphernalia, online antiques traders and sellers of historical replicas.

Supplemental Terms

1. You will allow PayPal to access your website through manual observation, automated “spidering”, or other automated search techniques in order to confirm the accuracy of content. However, PayPal is not obligated to monitor the accuracy of your website.
2. Your standard Merchant agreement must contain provisions for termination of the contract, with immediate effect, in the event a Merchant does not deliver the goods or services purchased, rejects complaints about goods or services without justification, or refuses to enable the return of goods without justification.
3. The TrustPay Service may be terminated without reason with a notice period of three (3) weeks.
4. You shall at all times cooperate with PayPal to investigate any suspected illegal, fraudulent, or improper activity by any person accessing the TrustPay Service.
5. You must clearly disclose on your website:
   1. your merchant identification data;
   2. full specification of the offered goods and/ or services, including their price and the clearing currency;
   3. description of the complaint procedure/ and return of goods or services, including information on consumer rights;
   4. method of refunding (returning) payments received from the Merchant’s Customers;
   5. customer service contact information;
   6. export restrictions, if any, imposed on the offered goods; and
   7. method of delivery of the goods/services provided
6. You warrant that neither you, nor your directors nor your beneficial owners are subject to the consolidated list of persons, groups, and entities subject to EU financial sanctions as published by the European Commission and the European External Action Service.
7. TrustPay shall be entitled to not to credit or transfer funds to PayPal for your benefit, if: (1) the data about the payer is not clear, comprehensible, and specific enough,; or if (2) the Transaction contradicts applicable law, or if (3) there is a reasonable suspicion that the relevant Transaction is associated with money laundering, terrorism financing, or other criminal activity.