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Legal

  • Terms and conditions
  • Website terms of use
  • Terms of business
  • Privacy
  • Disclaimer
  • Cookies
  • Security awareness
  • Card terms and conditions

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
Spush

Spush is a division of Spoynt Limited. Spoynt Limited is a company registered in England with company number 14156599.

Spoynt Limited is authorized and regulated by the Financial Conduct Authority, under the Electronic Money Regulations 2011, the United Kingdom 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.

Electronic money issued by the Principal E-money Issuer institution (EMI) is not covered by the Financial Services Compensation Scheme (FSCS).

In order to protect money held in electronic money accounts, it is safeguarded by the issuing organization. Safeguarding means that, by law, all your money has to be kept in accounts that are completely separate from the ones used to run the business. So your money is backed by assets that the e-money issuer holds in separate accounts. These funds are called ‘safeguarded funds’.

Card services on Spush are provided in partnership with Wirex. In the UK, Cards are issued by Wirex Limited, authorised and regulated by the Financial Conduct Authority under the Electronic Money Regulations 2011 (FRN 902025).

Card funds are held in an account created for you by the Card Issuer, to which only you have access. Spush does not hold or have access to these funds.

You must be at least 18 years old to open, operate and hold a Spush Account and Card.

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