Legal

Introduction and scope

Dovo SA provides foreign-currency accounts, cross-border payouts, cards and stablecoin functionality to eligible business customers ("Business Customers", "you", "your") so that they can receive and make payments, subject to eligibility (the "Services").

Whether you are eligible depends on what your business actually does, the sector it operates in, where it is incorporated, where it trades, who its customers are, how it moves money, the anti-money-laundering and counter-terrorist-financing law that applies to us, our own risk appetite, and any other criterion we reasonably apply.

This Acceptable Use Policy (the "Policy") sets out the permitted and prohibited uses of the Dovo platform (the "Platform") and the Services. It binds every Business Customer and, through them, their directors, officers, shareholders, employees, contractors, agents and any Authorised User operating under a Dovo account.

By accessing or using the Services you agree to follow this Policy and every law that applies to you. If you do not agree with it, stop using the Services — continuing to use them is acceptance of this Policy and of the other documents that make up our agreement.

Business verification and eligibility

Dovo exists to move legitimate business money. We do not support businesses whose source of funds, business model or purpose for a payment is unclear, unverifiable or evasive under questioning.

You must give us complete, accurate and current information about your business, including:

1. Certificate of incorporation or equivalent registration documents.
2. Tax identification number and registered business address.
3. Details of directors, shareholders and beneficial owners.
4. The nature of your operations and the source of your funds.
5. Expected transaction volumes, corridors and payment flows.
6. Your customer profile, where the model makes that relevant.
7. Contracts, invoices or other evidence that the business trades.
8. Anything further we reasonably ask for.

We may decline an application or pause onboarding where we are not satisfied that the intended use of the Platform is legitimate and compliant. Access is granted, and kept, only while what you actually do on the Platform matches what you told us you would do.

Permitted uses

Subject to this Policy and to applicable law, a Dovo account may be used for legitimate business purposes, including:

1. Receiving payment from customers, clients and business partners for goods and services.
2. Receiving the proceeds of trade, consulting, professional services and export income.
3. Receiving payouts from e-commerce platforms, freelance platforms and marketplaces, where that activity is part of your business.
4. Paying suppliers, vendors, contractors, service providers and partners.
5. Receiving revenue and making operating payments, including payroll and overheads where we have enabled them.
6. Receiving investment proceeds or capital inflows that are lawful, verifiable and approved by us in advance.

Depending on your industry, your transaction profile or the jurisdictions you trade with, we may require additional review before enabling any of the above.

Account responsibility and Authorised Users

Use of the account by the Business

Everything done through your Dovo account is treated as done by you, the registered Business Customer. You are responsible for making sure that every person with access complies with this Policy and with the law.

Access controls

Only your directors, employees and duly authorised representatives may access the Platform on your behalf. You must ensure that:

1. Login credentials and API keys never leave your organisation.
2. Access rights are limited to people who need them, and revoked the day they no longer do.
3. An internal approval process exists for payments and for changes to account settings.

Dovo is not responsible for loss arising from misuse of your account, internal fraud, compromised credentials or unauthorised access. If you suspect any of those, tell us immediately so that we can restrict, investigate or suspend the account.

No third-party payment processing

You may not use the Services to:

1. Process payments on behalf of third parties.
2. Act as a payment intermediary, aggregator, escrow agent or collection agent.
3. Receive funds for the benefit of an unrelated person or business.
4. Offer "wallet" or banking-like services to third parties.

Some payment facilitation models — marketplaces, licensed payment institutions, SaaS subscription billing — can be approved case by case, subject to enhanced due diligence and our written approval.

One account per entity

A legal entity may hold one Dovo account, unless we have agreed in writing to more. Where we find duplicates, we may suspend, close, consolidate or merge them.

Restricted activities

The Platform is for lawful business purposes only. You may not use it:

1. In any way that breaches a local, national or international law or regulation, or that causes Dovo to breach one.
2. For unlawful, fraudulent, deceptive, dishonest or misleading activity.
3. To conceal or disguise the origin, ownership or destination of funds.
4. To facilitate money laundering, terrorist financing, tax evasion or sanctions circumvention.
5. To send or receive funds connected to bribery, corruption or political exposure without disclosure and approval.
6. To send unsolicited advertising, promotional material or spam.
7. To distribute malware, spyware or any other harmful code.
8. In a way likely to generate disputes, reversals, chargebacks, complaints, penalties or liabilities for Dovo, for other customers or for third parties.
9. In a way inconsistent with the business purpose and transaction profile you declared to us.

Restricted lines of business

Dovo does not support transactions connected, directly or indirectly, to the following ("Restricted Businesses"). The list is illustrative rather than exhaustive.

1. Criminal or illegal activity of any kind — including narcotics, child sexual exploitation material, human trafficking, terrorist financing, stolen goods or funds, illegal wildlife trade, and smuggling or unlawful import and export.
2. Gambling, sports betting, lotteries, gaming operations and the payment processing behind them.
3. Currency exchange, money transmission and money services businesses — including FX dealing, remittance operations, bureaux de change, crypto exchange or brokerage, and virtual asset service provider activity, unless expressly approved by us in writing.
4. Investment schemes, Ponzi and pyramid schemes, and any offering that promises returns it cannot deliver.
5. Counterfeit goods, piracy, copyright and trade mark infringement, and imitation products.
6. Unauthorised resale of event tickets and ticket scalping.
7. Firearms, firearm parts and accessories, ammunition, explosives and weapons.
8. Adult entertainment, pornography, escort services and prostitution.
9. Sale, distribution or promotion of prescription drugs, controlled substances and pharmaceutical products, unless properly licensed and approved by us.
10. Unlicensed financial services — dealing in securities, derivatives or commodities, investment advice without authorisation, lending and loan-sharking, and unlicensed insurance.
11. Any product or service that promotes hate, violence, racial intolerance, extremism or discrimination.
12. Anything illegal, or marketed in a way that would create regulatory liability for Dovo.

High-risk business models

Some industries are supported only with our prior written approval, enhanced due diligence and closer transaction monitoring. These include:

1. Marketplace platforms.
2. Digital asset businesses holding clear licences.
3. Fintech infrastructure providers.
4. Cross-border logistics and export businesses.
5. Businesses operating in high-risk jurisdictions.
6. Charities and non-governmental organisations.
7. Politically exposed industries.

We may ask for more documentation, impose lower limits, or decline such a business entirely.

Monitoring, enforcement and suspension

We monitor account activity and transaction behaviour to check compliance with this Policy, with the law and with our regulatory obligations.

Where we determine that you have breached this Policy or that your account presents a compliance risk, we may:

1. Suspend or restrict the account.
2. Freeze funds pending investigation or regulatory reporting.
3. Decline, reverse or cancel transactions.
4. Require additional documentation or an explanation.
5. Terminate the relationship without liability.
6. Report suspicious activity to the competent authority where the law requires it.

Reporting and cooperation

You agree to give us, promptly, the information and documents we need to:

1. Verify that a transaction is legitimate.
2. Confirm the source of funds and the nature of a payment.
3. Meet our own regulatory and compliance obligations.

Failing to cooperate with a compliance request is itself grounds for suspension or termination.

Disclaimer

We are under no obligation to monitor your use of the Services for your benefit or for anyone else's, and we disclaim responsibility for misuse of the Services by you or by an Authorised User on your account.

That said, we reserve the right — without undertaking any duty — to monitor, review, screen, investigate, restrict or block transactions, accounts, communications, data and content passing through the Services, in order to comply with the law, with a regulatory obligation, with our internal risk policies, or with a lawful request from a competent authority.

We are not responsible for content, instructions, payment details, references, documentation or other material created, stored, transmitted or made accessible by you or by a third party through the Services, and we exercise no editorial control over it.

Where we become aware that activity or material breaches this Policy, we may remove it, suspend or terminate access, block the account, freeze or restrict transactions, and report the breach to law enforcement or a regulator, without liability.

Unless this Policy or a signed agreement says otherwise, we owe no duty to any person who has not entered into a contractual relationship with us for the use of the Services. To the fullest extent the law allows, we exclude liability for loss, damage, claim, penalty or expense arising from your breach of this Policy or from the acts and omissions of your employees, agents, contractors and Authorised Users.

Updates to this Policy

We may update or revise this Policy to reflect changes in the law, in our operations or in the Platform. An update takes effect when it is posted here, or as otherwise communicated to you.

Where the law requires it, we will notify you of a significant change. Continued use of the Services after a change means you accept the revised Policy.

Contact

Questions, concerns or reports about this Acceptable Use Policy go to business@getdovo.com.