Compliance and Acceptable Use Policy

Last Modified: 13 March 2024

This Compliance and Acceptable Use Policy (“CAUP”) is between Tipalti and Customer and applies to the use of the Tipalti Services as a part of the Tipalti Services Agreement (together, the “Agreement”). Tipalti may amend this CAUP at any time by posting a revised version on its website. The revised version will be effective at the time it is posted. In addition, if the revised version includes a Substantial Change, Tipalti will provide Customer with 30 calendar days’ prior notice of the Substantial Change. All capitalized terms not defined herein are defined in the Tipalti Services Agreement.

1.     Compliance and AML.

1.1. To help governments fight the funding of terrorism and money laundering activities, laws require financial institutions, including money services businesses and electronic money institutions, banks, and certain other service providers to obtain, verify, and record information that identifies every customer.
1.2. Tipalti may collect, store, and review, and use third parties to collect, store, and review, Customer, Supplier, and Transaction information to (1) determine that the Services will not be and are not being used for illegal purposes or purposes that expose Tipalti, Tipalti Bank, or its other suppliers to excessive risk, (2) combat fraud or abuse arising from the use of the Services, (3) to establish and operate reasonable anti-money laundering (AML) and know-your-customer (KYC) programs, and (4) comply with Applicable Laws. Without liability to Customer, Tipalti may condition the provision of its Services at any time on its review of such information and may decline to provide Services at any time to Customer for failure to complete or pass AML or KYC program requirements to Tipalti’s satisfaction.
1.3. Throughout the Term hereof, Tipalti may conduct ongoing and additional reviews of the Customer and its use of the Services under its AML program. Customer shall cooperate in these reviews of Customer or Payees and provide all information that Tipalti reasonably requests in support of the review. Tipalti may suspend access or provision of the Services if Customer is not cooperating in any such review or if the results of such review are unsatisfactory as determined by Tipalti, acting in its sole and absolute discretion. Customer shall supply Tipalti with information concerning Payees only as it relates to each Payee in a business capacity, and shall not include, or permit to be included any information concerning any individual acting in a nonbusiness capacity, such as in their capacity as a consumer, individual, or their family member acting on their own behalf for personal, family or household purpose.

2.  Acceptable Use Policy.  

2.1. Prohibited Activities. Customer shall not use the Services to conduct or contribute to any of the following activities, as determined by Tipalti in its sole discretion (collectively, “Prohibited Activities”):

  1. Any illegal activities, or in a manner that would be in violation of the Agreement or Applicable Laws;
  2. Involves or encourages infringement of an intellectual property right including, but not limited to sale or access of music, movies, software, video game or other virtual items when doing so would violate the terms and conditions of a third party agreement or intellectual property right, and any dealing in counterfeit goods;
  3. Using the Services to collect payments that support pyramid or Ponzi schemes, matrix programs, other “business opportunity” schemes or certain multi-level marketing programs;
  4. Using the Services in connection with or to make payments for drug paraphernalia; marijuana sales (even if legal in the state); escort services, porn or other adult content; internet sale of alcohol, tobacco or e-cigarettes; firearms; weapons; gambling; lotteries; or any goods with import/export restrictions;
  5. Using the Services to make payments to embassies, foreign consulates or other foreign governments;
  6. Using the Services in connection with consumer payments, virtual currency, e-wallets, stored value, quasi-cash, or any other money service business;
  7. Using the Services while impersonating any person or entity or falsely claiming an affiliation with any person or entity;
  8. Facilitating the sale, exchange, or distribution of items that encourage, promote, facilitate or instruct others to engage in illegal activity including, without limitation, drug trafficking, sex and human trafficking, arms trafficking, or laundering money;
  9. Promoting hate, violence, racial intolerance, or the financial exploitation of a crime in any manner whether directly or indirectly;
  10. Using the Services to assist in facilitating any of the foregoing; 
  11. Using any messaging function within the Services as a social messaging or chat service; or
  12. Using the Services in a manner that Tipalti deems to pose an unacceptable reputational, compliance, financial, or legal risk.