Terms Of Business
Effective from: 25 February, 2025
1. About Us
1.1 Our legal name is SPOYNT Ltd (“SPOYNT”). Our registered office is at:
71-75 Shelton Street, London, WC2H 9JQ, United Kingdom
Company registration number: 14156599
1.2 SPOYNT Ltd is registered with the UK Financial Conduct Authority under FRN 903071 as an EMD Agent, with rights to distribute or redeem electronic money (e-money) and provide certain payment services on behalf of an e-money institution, Noveba Limited, FRN 900924.
1.3 You may contact us at any time by writing to us at the above address or sending an email to our Support Team (payment@spoynt.com). Contact details are available in the FAQ section of our website.
2. Regulated Activities
2.1 SPOYNT Ltd operates as an EMD Agent with rights to distribute or redeem electronic money (e-money) and provide certain payment services on behalf of an e-money institution.
- FRN: 903071 (https://register.fca.org.uk/s/firm?id=0014G0000323qkeQAA )
- Regulator: Financial Conduct Authority
- Effective From: 01/04/2021
Principal Firm Details:
- Name: Noveba Limited
- Company Number: 11610200
- Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, UNITED KINGDOM
- Companies House Ref: https://beta.companieshouse.gov.uk/company/11610200
- Type: EMD
- FRN: 900924
- Current status: Authorised Electronic Money Institution A firm that we have given permission to issue electronic money (e-money) and provide payment services.
- Regulator Name: Financial Conduct Authority
- Effective From: 16/08/2019
- Reference: https://register.fca.org.uk/s/firm?id=0010X00004JBGVaQAP
3. Codes of Conduct
3.1 SPOYNT Ltd is subject to legislative requirements under the Electronic Money Regulations 2011 and the Payment Services Regulations 2017.
4. Fees and Charges
4.1 SPOYNT Ltd applies fees and charges to its products and services. Details are available in the Fees section of our website. These fees may be amended periodically.
5. Data Protection Notice
5.1 The personal information requested from you is required for account opening checks. We will process your data in compliance with the Data Protection Act 2018.
6. Complaints
6.1 You may submit complaints via:
- In writing (letter or email)
- Verbally
6.2 Your complaint will be investigated by SPOYNT Ltd, and an acknowledgment letter will be sent to you. If unresolved within 35 business days, you may escalate your complaint to the Financial Ombudsman Service, Exchange Tower, London, E14 9SR.
7. Changes to Terms of Business
7.1 Any material changes will be notified via email, website notices, or the app.
Appendix A – List of Prohibited Jurisdictions
Customers and/or transactions that have a direct and clear link (e.g., entity/asset ownership, UBO, business ties, or other strong relationships) to the following jurisdictions are subject to the following service supply status:
| Country / Territory | Client Account Opening & Maintenance | Transactions (Incoming / Outgoing / Exchange) | Notes |
|---|---|---|---|
| Abkhazia | PROHIBITED | PROHIBITED | |
| Afghanistan | PROHIBITED | PROHIBITED | |
| Andorra | ALLOWED* | ALLOWED* | Subject to Enhanced Due Diligence (EDD) on a case-by-case basis |
| Anguilla | PROHIBITED | PROHIBITED | |
| Antigua and Barbuda | PROHIBITED | PROHIBITED | |
| Armenia | PROHIBITED | ALLOWED* | Subject to EDD on a case-by-case basis |
| Azerbaijan | PROHIBITED | ALLOWED* | Subject to EDD on a case-by-case basis |
| Aruba | PROHIBITED | PROHIBITED | |
| Bahamas | PROHIBITED | PROHIBITED | |
| Bahrain | ALLOWED* | ALLOWED* | Subject to EDD on a case-by-case basis |
| Barbados | PROHIBITED | PROHIBITED | |
| Belarus | PROHIBITED | PROHIBITED | |
| Belize | PROHIBITED | PROHIBITED | |
| Bermuda | PROHIBITED | PROHIBITED | |
| British Virgin Islands | PROHIBITED | PROHIBITED | |
| Burundi | PROHIBITED | PROHIBITED | |
| Cayman Islands | PROHIBITED | PROHIBITED | |
| Central African Republic | PROHIBITED | PROHIBITED | |
| Cook Islands | PROHIBITED | PROHIBITED | |
| Cuba | PROHIBITED | PROHIBITED | |
| Democratic Republic of the Congo | PROHIBITED | PROHIBITED | |
| Djibouti | PROHIBITED | PROHIBITED | |
| Egypt | PROHIBITED | PROHIBITED | |
| Eritrea | PROHIBITED | PROHIBITED | |
| Ethiopia | PROHIBITED | PROHIBITED | |
| Gaza Strip | PROHIBITED | PROHIBITED | |
| Guatemala | PROHIBITED | PROHIBITED | |
| Guinea | PROHIBITED | PROHIBITED | |
| Haiti | PROHIBITED | PROHIBITED | |
| Iran | PROHIBITED | PROHIBITED | |
| Iraq | PROHIBITED | PROHIBITED | |
| Ivory Coast (Côte D’Ivoire) | PROHIBITED | PROHIBITED | |
| Jamaica | PROHIBITED | PROHIBITED | |
| Kenya | PROHIBITED | PROHIBITED | |
| Kuwait | ALLOWED* | ALLOWED* | Subject to EDD on a case-by-case basis |
| Lebanon | PROHIBITED | ALLOWED* | Subject to EDD on a case-by-case basis |
| Liberia | PROHIBITED | PROHIBITED | |
| Libya | PROHIBITED | PROHIBITED | |
| Macau | PROHIBITED | PROHIBITED | |
| Maldives | PROHIBITED | PROHIBITED | |
| Mali | PROHIBITED | PROHIBITED | |
| Mauritius | PROHIBITED | PROHIBITED | |
| Moldova (including Transnistria) | PROHIBITED | PROHIBITED | |
| Monaco | PROHIBITED | PROHIBITED | |
| Myanmar (Burma) | PROHIBITED | PROHIBITED | |
| North Korea | PROHIBITED | PROHIBITED | |
| Pakistan | PROHIBITED | PROHIBITED | |
| Panama | PROHIBITED | PROHIBITED | |
| Russian Federation | PROHIBITED | PROHIBITED | |
| Seychelles | PROHIBITED | PROHIBITED | |
| Somalia | PROHIBITED | PROHIBITED | |
| South Ossetia | PROHIBITED | PROHIBITED | |
| Sudan | PROHIBITED | PROHIBITED | |
| Syria | PROHIBITED | PROHIBITED | |
| Ukraine (excluding Donetsk & Luhansk regions) | ALLOWED* | ALLOWED* | Subject to EDD on a case-by-case basis, excluding war-affected territories |
| Ukraine – Donetsk & Luhansk region territories | PROHIBITED | PROHIBITED | |
| United Arab Emirates | ALLOWED* | ALLOWED* | Subject to EDD on a case-by-case basis |
| United States of America | ALLOWED | ALLOWED* | Subject to EDD on a case-by-case basis for clients with US citizenship/residency |
| Venezuela | PROHIBITED | PROHIBITED | |
| Yemen | PROHIBITED | PROHIBITED |
The list above is subject to regular change / update.
Important:
Being a part of the global financial system, SPOYNT Ltd Limited relies on external financial/payment partners for performing certain operations (including transfers and accounts). It is SPOYNT Ltd’s obligation to adhere to partners’ policies and terms of business, thus, SPOYNT Ltd reserves the right to refuse its Clients certain actions and prohibit transactions as required by its partners terms and conditions.
Appendix B – Prohibited Business/ Transactions
SPOYNT Ltd will not provide account or payment services to entities operating in or related to the following sectors/industries:
| Type of Business | Reason |
|---|---|
| Anonymous or Numbered Accounts, unincorporated or unregistered entities, Shell Banking (i.e., banks incorporated in a jurisdiction without a physical presence and unaffiliated with a regulated financial group) | Restricted / High-risk |
| Cash and Check Handling: Check Cashing, Deposit Taking, Cash Transfer | Restricted / High-risk |
| Credit repair, Debt Restructuring, Debt Recovery, Debt Settlement, Debt Collections | Restricted / High-risk |
| Embassies, Consulates, and other Governmental Bodies | Restricted / High-risk |
| Tobacco, E-Cigarettes, and E-Liquid | Restricted / High-risk |
| Operating a business requiring a license or special permit without obtaining such a license (e.g., Unregulated Auction Houses) | Restricted / High-risk |
| Production of Adult or Violent Content | Restricted / High-risk |
| Production or Distribution of Offensive Weapons: Ammunition, Firearms, Explosives, Complex Weapons (e.g., guided missiles), Poisons | Restricted / High-risk |
| Transactions involving Human Organs | Illegal |
| Sanctioned Individuals and Entities | Restricted |
| Services of Psychic Services, Occult, Pseudo-Sciences, Alternative Medicine | Other |
| Financial Pyramid or Ponzi Schemes | Illegal |
| Any industry known to be illegal in its local jurisdiction or the UK | Illegal |
| Illegal Drugs and Narcotics | Illegal |
| Supply, Sale, and Distribution of certain Recreational Drugs (including lawful medicinal marijuana distributors) | Legal in certain jurisdictions |
| The sale or distribution of Stolen Goods (including digital and virtual goods), Counterfeit Goods, or Violation of Intellectual Property Rights | Illegal |
| Selling, Hosting, Distributing, Producing, or Promoting Offensive Materials, including those inciting racial hatred or discrimination based on gender, race, religion, national origin, physical ability, sexual orientation, or age | Illegal |
| Alternative / Informal / Unregulated Payment Systems (e.g., Hawala, Chit, Poey Kuan, Hundi, Fei Chi ‘Ien’) | High Risk / Illegal |
| Virtual Currency Exchanges, Administrators, or Miners and/or Cryptoasset Exchange Providers or Custodian Wallet Providers that are not licensed or regulated in an equivalent jurisdiction | Illegal |
| Illegal, Unregulated, Unlicensed, or Unauthorized Gambling or Gaming Firms | Illegal |
| Trafficking of Cultural Artefacts and/or Wildlife or Protected Species | Illegal |
| Offenders of Environmental Regulations and Perpetrators of Environmental Crime | Illegal |
| Human Trafficking, Modern Slavery, Unlicensed Migration / Employment Agencies | Illegal |
| Unincorporated Entities | Not allowed |
| Entities with Complex Ownership Structures where the UBO is separated by over three layers of ownership and control | Not allowed |
| Legal Entities with Complex Ownership/Management Structures that lack apparent commercial rationale and obstruct CDD disclosure and UBO identification | Prohibited |
Appendix C – High-Risk-Business / Transactions
Provision of payment and account services related to the following industries and types of activities may be subject to separate EDD (Enhanced Due Diligence) / KYB (Know Your Business) / KYCC (Know Your Customer’s Customer) / Risk Analysis and Banking Provider’s Approval.
| Type of Business | Risk Level |
|---|---|
| Licensed Cryptocurrency Exchanges, Platforms, and Crypto Payments | High Risk / High Volatility |
| High-Value Dealers (Jewelry, Art, Auctions, Automotive) | High Risk |
| Crowdfunding / Crowd Investing Platforms | High Risk |
| Second-Hand Vehicle Sales | High Risk |
| Extractive Industries (Mining, Crude Oil/Gas) | High Risk |
| Cash-Intensive Businesses (Cash-and-Carry, Scrap Metal, Beauty Industry) | High Risk |
| Professional Sports | High Risk |
| Payroll Operators, Licensed HR Consultants | High Risk |
| Tour Operators | High Risk |
| Charities, Non-Profit Organizations, Foundations, and Cultural Associations (including donation-based entities) | High Risk |
| Professional Providers of Corporate Services, Tax Advisory, Citizenship by Investment, Legal Advisory | High Risk |
| Legal Entities using Nominee Directors / Secretaries / Shareholders | High Risk |
| Penny Stocks or Microcap Securities | High Risk |
| Payments involving General Trading Companies operating in Free Trade Zones (FTZ) | High Risk |
| Regulated Payment Service Providers / Money Service Businesses (MSBs) | Regulated / High Risk |
| Payments involving Downstream Processing for Correspondent Banks, MSBs, Financial Institutions, and Payment Service Providers that are not otherwise prohibited | Regulated / High Risk |