1. Purpose

GaulBridge Ltd. ("GaulBridge", "we", "us") provides payment, foreign exchange, multi-currency and card services to personal and business clients. This Acceptable Use Policy ("AUP") sets out the rules for using those services — what is permitted, what is not, and what happens if these rules are breached.

These rules exist to protect our clients, our business, and the integrity of the financial system. They reflect our obligations under Canadian law, FINTRAC requirements, and the requirements of our payment infrastructure partners.

2. Who this applies to

This policy applies to all GaulBridge account holders — personal and business — and to any person or entity acting on behalf of an account holder. By using our services, you confirm that you have read this policy and agree to comply with it.

If you are a business client, you are responsible for ensuring that all employees, directors, agents, and authorised users who access your GaulBridge account also comply with this policy.

3. Permitted use

GaulBridge services may only be used for lawful purposes. Permitted uses include:

• Sending and receiving personal remittances and payments
• Making and receiving legitimate business payments, including supplier payments, payroll, and invoice settlement
• Foreign exchange conversion for personal or business purposes
• Holding multi-currency balances for legitimate personal or business use
• Using pre-paid cards for personal or business expenditure
• Processing batch payments for legitimate business operations

All use of GaulBridge services must be consistent with your stated account purpose and the information you provided during onboarding. If your business activities change materially, you must notify us.

4. Prohibited use

4.1 Financial crime

• Money laundering or any activity designed to conceal the origin or destination of funds
• Terrorist financing or providing funds or services to designated individuals or organisations
• Fraud, including identity fraud, account takeover fraud, push payment fraud, and invoice fraud
• Tax evasion or facilitating the tax evasion of any person or entity
• Bribery, corruption, or facilitation payments
• Processing proceeds of any criminal activity

4.2 Sanctions violations

• Transacting with any individual, entity, or organisation designated under Canadian sanctions and terrorist-listing instruments — the Special Economic Measures Act (SEMA), the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law), regulations under the United Nations Act, the Freezing Assets of Corrupt Foreign Officials Act and the Criminal Code list of terrorist entities — or listed by the UN Security Council, the EU, the UK or the US Office of Foreign Assets Control (OFAC). We screen clients, beneficial owners, counterparties and transactions at onboarding, on every transaction, on a periodic basis and whenever a list is updated
• Sending or receiving funds to or from a prohibited jurisdiction (see Section 6)
• Attempting to circumvent sanctions controls through third parties, shell companies, or indirect routing
• Providing financial services to sanctioned persons or entities, directly or indirectly

4.3 Deception and misuse

• Providing false, misleading, or incomplete information at onboarding or at any point during the relationship
• Using your account for purposes other than those stated during onboarding without prior notification
• Impersonating another person or entity
• Using another person's account or credentials without authorisation
• Structuring transactions to avoid reporting thresholds or detection
• Using our services in a way designed to circumvent our controls or those of any regulatory authority

4.4 Prohibited transactions

• Payments related to unlicensed gambling, illegal lotteries, or prohibited gaming activities
• Payments for illegal drugs, controlled substances, or related paraphernalia
• Payments for weapons, arms, or military equipment without appropriate licensing
• Transactions involving child exploitation material or any illegal content
• Payments for services that are illegal in the sender's or recipient's jurisdiction
• Payments to or from unregistered or unlicensed financial services providers
• High-yield investment programme (HYIP) transactions or Ponzi scheme-related payments

4.5 Politically exposed persons and third parties

As part of onboarding and ongoing monitoring we determine whether you, a beneficial owner or an authorised signatory is a politically exposed person (domestic or foreign) or the head of an international organisation, or a family member or close associate of one, and we ask whether you act on behalf of, or at the instruction of, a third party. You must answer these questions truthfully and tell us if the position changes. Where a determination is positive we apply enhanced measures, establish source of wealth and funds, and require senior-management approval before the relationship or transaction proceeds.

5. Prohibited business types

GaulBridge does not provide services to the following business types, regardless of jurisdiction:

• Unregistered or unlicensed money services businesses (MSBs), currency exchanges, or payment processors
• Shell banks — banks with no physical presence in any jurisdiction
• Businesses primarily engaged in cash-intensive activities where the source of funds cannot be verified
• Anonymous or bearer share companies where ultimate beneficial ownership cannot be established
• Businesses involved in the manufacture, sale, or distribution of illegal weapons or controlled substances
• Businesses providing services to sanctioned persons, entities, or jurisdictions
• Businesses whose primary activity is mixing, tumbling, or obfuscating the origin of digital assets
• Any business that is unlicensed for the regulated activity it is conducting

If you are uncertain whether your business type is eligible, please contact us at compliance@gaulbridge.com before applying.

6. Jurisdiction restrictions

GaulBridge applies jurisdiction-based restrictions to all accounts and transactions. These restrictions reflect our regulatory obligations, our payment infrastructure requirements, and our own risk framework.

Jurisdiction status is reviewed regularly and may change. The current status of all jurisdictions is set out below. If your jurisdiction is not listed as supported, please contact us before applying.

These lists are derived from GaulBridge's business-based risk assessment and are reviewed at least annually and whenever law, regulatory guidance or sanctions designations change. We will give reasonable notice of material changes; jurisdiction lists may change without notice where required by law or by a sanctions designation. Payments already accepted for processing before a corridor closes will be completed or returned to the sender. GaulBridge reserves the right to restrict or terminate services to any jurisdiction at any time.

Ministerial Directives: transactions involving jurisdictions or entities subject to a Ministerial Directive issued under Part 1.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (currently including Iran and North Korea) are subject to the enhanced measures and reporting those Directives require, in addition to the restrictions above.

United States: GaulBridge does not provide services to U.S. persons or to entities incorporated in the United States or its territories.

7. Digital asset services

GaulBridge does not currently offer digital asset services. Where GaulBridge has entered into a separate written agreement with a client for such services, that agreement governs and this policy continues to apply. Requests to send, receive, exchange or settle digital assets outside such an agreement cannot be accommodated. Businesses whose primary activity is mixing, tumbling or obfuscating the origin of digital assets remain prohibited (Section 5).

8. Monitoring and enforcement

GaulBridge continuously monitors transactions and account activity to detect suspicious behaviour, sanctions breaches, and violations of this policy. We use automated screening tools and manual review processes.

If we identify or suspect a breach of this policy, we may:

• Block or delay an individual transaction pending investigation
• Request additional information or documentation from you
• Suspend your account temporarily while we investigate
• Terminate your account with notice, or immediately where required by law
• Return funds to their source where legally permitted
• Report the matter to FINTRAC, law enforcement, or other relevant authorities as required by law

We may be prohibited by law from informing you that a report has been made to a regulatory authority or law enforcement agency.

9. Reporting concerns

If you become aware of any activity that may breach this policy — whether relating to your own account or another party — please report it to us immediately.

• Compliance concerns: compliance@gaulbridge.com
• Account security issues: support@gaulbridge.com
• Whistleblowing: see our Whistleblowing Policy for anonymous reporting options

10. Changes to this policy

GaulBridge may update this Acceptable Use Policy at any time to reflect changes in law, regulation, our payment infrastructure, or our risk framework. We will give you reasonable notice of material changes. Your continued use of our services after the effective date of any change constitutes acceptance of the revised policy.

Jurisdiction lists may change without notice where required by law or by a sanctions designation (see Section 6); payments already accepted for processing before a corridor closes will be completed or returned to the sender.

11. Contact

For questions about this policy or to check whether a specific use case or jurisdiction is permitted: