1. Purpose & Scope
This Policy defines the types of business activity, transactions, and service models that FrontierFi LLC d/b/a Frontr (“Frontr”) does not permit on its platform, APIs, or related services.
It forms part of our broader compliance and risk-control framework, which includes KYC/KYB onboarding, AML/CTF screening, sanctions monitoring, and transaction monitoring.
The purpose of this Policy is to ensure Frontr, its customers, banking partners, and service providers remain compliant with:
- U.S. and international AML/CTF regulations (e.g., BSA, FinCEN, FATF)
- OFAC, EU, U.K., U.N., and other global sanctions regimes
- Applicable money transmission, payments, consumer protection, and financial services laws
These prohibitions apply globally to all users, beneficial owners, directors, signatories, and counterparties using Frontr’s Services.
2. Prohibited Business Categories
The following categories of use are prohibited on the Frontr platform. This list is non-exhaustive; we may restrict other activities at our discretion.
| # | Category | Description (examples) |
| 1 | Adult Content & Sexual Services | Pornographic content, escort services, sexually explicit tokens/NFTs, or platforms facilitating commercial sex acts. |
| 2 | Drugs & Controlled Substances | Sale, brokerage, or tokenization of narcotics, cannabis (where illegal), unlicensed pharmaceuticals, or “legal highs.” |
| 3 | Weapons, Ammunition & Explosives | Financing or distribution of firearms, explosives, military-grade components, or dual-use technology. |
| 4 | Unlicensed Gambling | Casinos, lotteries, betting platforms, fantasy sports, or games of chance not explicitly licensed in the user’s jurisdiction. |
| 5 | Fraudulent Schemes | Ponzi or pyramid structures, HYIPs, ransomware proceeds, spoofing, wash trading, or coordinated fraud. |
| 6 | Hate, Violence, Terrorism & Extremism | Promotion or funding of terrorism, extremist ideology, hate crimes, or related organizations. |
| 7 | Illegal or Harmful Activities | Human trafficking, child exploitation, wildlife trafficking, or any activity criminalized by law. |
| 8 | Sanctions Violations | Transactions involving sanctioned persons, wallets, or jurisdictions (e.g., OFAC, EU, U.K., U.N.). |
| 9 | Identity Fraud & Obfuscation | Use of shell/nominee structures, fake identities, or anonymity tools to evade KYC/KYB. |
| 10 | High-Risk Lending & Predatory Finance | Payday loans, unlicensed lending/borrowing platforms, predatory APR products. |
| 11 | Political & Government Entities (Restricted) | Transactions involving sovereign wealth funds, state-owned enterprises, or PEP-linked entities without enhanced due diligence and prior approval. |
| 12 | Data Misuse & Privacy Violations | Sale of stolen data, surveillance tools, or activities violating GDPR/CCPA or equivalent standards. |
| 13 | IP Infringement & Counterfeit Goods | Sale or tokenization of counterfeit goods, pirated content, or IP-infringing assets. |
| 14 | Anonymity-Enhanced Assets | Mixing/tumbling services, privacy tokens lacking auditability, or obfuscation tools unless explicitly approved. |
| 15 | Unregistered Securities & Derivatives | Tokenized securities, swaps, or other instruments requiring registration unless appropriately licensed/exempt. |
3. Consequences of Violation
If we determine a user has engaged in prohibited activity, we may take one or more of the following actions:
- Immediate Account Suspension – halt of all transaction capability.
- Compliance Review – including transaction forensics, partner notifications, and enhanced due diligence.
- Termination – permanent closure of accounts associated with the activity.
- Asset Sequestration – retention or transfer of assets if required by law.
- Regulatory Reporting – suspicious activity may be reported to regulators (e.g., SARs/STRs) without notice.
- Partner Disclosure – banks, payment processors, and service providers may be alerted to mitigate risk.
4. How to Report Suspected Violations
If you observe or suspect prohibited activity on the Frontr platform, please report it immediately to:
Reports are confidential and handled by our Compliance team.
By using Frontr’s Services, you confirm your compliance with this Prohibited Activities Policy. We reserve the right to update this Policy at any time as laws, regulations, or partner requirements evolve.