Archived version

Acceptable use policy

Version 1.0

The text is reproduced verbatim, unformatted, because that is exactly what was hashed: any prettifying would open a gap between what you read and what is proven.

# Acceptable use policy
version: 1.0
updated: 2026-08-12
description: Prohibited uses of CowriePay, activities requiring prior approval, and the consequences of a breach.

## 1. Purpose
This policy defines the prohibited uses of CowriePay. It forms an integral part of the [Terms and conditions](/legal/terms) and binds the Client as well as the users it authorises.
These restrictions are not a judgement on any activity. They follow from the law, from our anti-money-laundering and counter-terrorist-financing due-diligence obligations, and from the requirements of the infrastructure the service relies on.
The lists below are indicative and not exhaustive: an activity that does not appear but presents the same risks is treated the same way.
CowriePay is operated by COWRIEX, a Societe par Actions Simplifiee (SAS) registered with the Trade and Personal Property Credit Register of Abomey-Calavi under number RB/ABC/25 B 10127. Full details appear in the [Legal notice](/legal/legal-notice).

## 2. Prohibited users
The service may not be opened or used by:
- any individual or entity appearing on an applicable sanctions list, and any entity owned or controlled by such a person;
- any person acting, directly or indirectly, on behalf of a person referred to above;
- any person established, resident or operating from a country or territory subject to comprehensive restrictive measures;
- any person who refuses to provide the information and supporting documents needed for verification, or who provides inaccurate information;
- any person whose account was previously closed for breach of this policy.

## 3. Prohibited activities
CowriePay may not be used, directly or indirectly, for:
- money laundering, terrorist financing or the financing of the proliferation of weapons of mass destruction;
- circumventing international sanctions, restrictive measures or export controls;
- fraud, scams, phishing, identity theft or any form of deception aimed at obtaining funds;
- extortion, distribution of malware or the collection of ransoms;
- asset-mixing services and, more generally, any arrangement designed to break the traceability of the origin of funds;
- clandestine marketplaces and the sale of unlawful goods or services;
- trade in narcotics, weapons, ammunition or controlled dual-use goods;
- human exploitation, trafficking, and the production or distribution of child sexual abuse material;
- pyramid schemes, Ponzi arrangements and any offer promising a guaranteed return;
- market manipulation and fictitious transactions intended to create the appearance of activity;
- gambling and betting carried on without the authorisation required in the relevant jurisdictions;
- the provision of financial services for which a licence is required, where the Client does not hold one;
- counterfeiting and any infringement of third-party intellectual property rights;
- collecting or holding funds on behalf of third parties outside the framework set out in article 5.

## 4. Activities requiring prior approval
The following activities are not prohibited but require our prior written approval following enhanced review. Carrying them on without that approval is a breach:
- duly authorised gambling and betting;
- money transfer services, bureaux de change and similar licensed activities;
- digital-asset exchange or custody platforms;
- marketplaces and any activity involving the collection and onward payment of funds to third parties;
- lawful adult content;
- trade in precious metals, precious stones and high-value goods;
- non-profit organisations raising funds internationally.

## 5. Client obligations towards its own customers
Where the Client uses CowriePay to serve its own customers, it must:
- verify the identity of its end customers in accordance with the regulation applicable to it;
- not give access to the service, directly or indirectly, to unverified third parties;
- not aggregate funds belonging to unidentified third parties in a single account;
- respond to our requests for information within a reasonable time, including on the origin of funds and the identity of beneficiaries;
- inform its end customers of the processing of their data, as set out in the [Privacy policy](/legal/privacy).

## 6. Technical abuse
It is also prohibited to:
- circumvent or attempt to circumvent rate limits, caps, withdrawal controls or any other security mechanism;
- reverse engineer the service, or conduct penetration testing without our prior written authorisation;
- resell, sublicense or otherwise make access to the service available to third parties outside the contractual framework;
- create multiple accounts in order to circumvent a refusal, suspension or closure decision;
- use the Sandbox environment for anything other than testing and integration.

## 7. Consequences of a breach
Depending on the seriousness and on the obligations incumbent on us, we may:
- open an enhanced review and request further information or supporting documents;
- refuse, hold or delay a transaction;
- suspend all or part of access to the service;
- terminate the contract and close the account;
- freeze assets and, where the law so requires, block them and make the required reports to the competent authorities.
Where the law prohibits us from informing a person of a report or a measure concerning them, we comply with that prohibition.

## 8. Reporting
If you become aware of any use of CowriePay contrary to this policy, report it to [email protected]. For a security incident or a phishing attempt, write to [email protected].

## 9. Changes
We may amend this policy to reflect changes in risks, fraud typologies and the applicable framework. Amendments take effect on publication on this page; in the event of a substantial change we inform the Client by email or in the dashboard.