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Legal

Acceptable Use

Effective September 23, 2026. Version 1.0. This policy is part of the Terms of Service. It lists the activities YembiPay will not settle, the activities it settles only with licence evidence and enhanced review, and the jurisdictions and persons it cannot serve.

Review status: draft published for partner and regulator reading. Independent legal review is a gated launch item and remains open; see the legal hub for status.

Why this policy exists

YembiPay moves value across borders on public networks and local rails, under the rules of stablecoin issuers, participating banks, and the regulators of each corridor. Some activities are unlawful in a corridor, some are outside the risk appetite of the rails we depend on, and some are lawful but require evidence before any rail will carry them. This policy exists so an organization can see before onboarding whether its business fits, and so a rail partner or regulator can see how we decide.

Prohibited activities

YembiPay does not settle value for, and will end the relationship of any organization found to be engaged in, the following. The list is illustrative of categories, not exhaustive.

  • Anything unlawful in the sending or receiving corridor, or that requires a licence the organization does not hold.
  • Unlicensed money transmission, informal value transfer, or agent-based remittance nested under another organization's credentials.
  • Payable-through arrangements, shell banks, and entities whose ownership cannot be established, including bearer-share entities.
  • Mixers, tumblers, privacy-coin conversion, and any service designed to obscure the origin or destination of funds.
  • Proceeds of token sales, mining, or staking; secondary trading of tokens; and any activity that would make YembiPay an exchange or broker for a third party.
  • Illegal goods and services, counterfeit goods, and infringement of others' intellectual property.
  • Fraud, deception, coercion, and any settlement whose beneficiary or purpose is misrepresented.
  • Structuring settlements to stay under limits or reporting thresholds.
  • Sexual services, human trafficking, and child exploitation in any form.
  • Weapons, ammunition, and controlled substances outside a licensed and disclosed supply chain.

Restricted activities

The following are lawful in at least one corridor but carry elevated risk. YembiPay settles them only after enhanced due diligence, on production of the licence or registration the corridor requires, with an agreed monitoring profile, and with the consent of the rail partner that will carry the payout. Approval is per organization and per corridor and may be withdrawn.

  • Licensed money transmitters, remittance companies, cambios and currency exchanges, payment facilitators, and aggregators.
  • Digital asset exchanges, custodial wallet providers, and other digital asset businesses.
  • Gaming, betting, and lottery operators licensed in their jurisdiction.
  • Dealers in precious metals and stones, including gold and diamond exporters.
  • Real estate, high-value goods, and vehicle dealers.
  • Charities, non-governmental organizations, and aid programmes sending funds into a corridor.
  • Lending, buy-now-pay-later, and debt collection.
  • Licensed cannabis and hemp businesses, where the US dollar leg creates bank-partner constraints even when the business is lawful locally.
  • Adult entertainment, tobacco, and alcohol.

Politically exposed persons and their close associates are subject to enhanced due diligence, senior approval, and closer monitoring. They are not automatically refused. In small jurisdictions, politically connected families run legitimate businesses, and a blanket ban would be both unfair and out of step with the standards our regulators apply.

Restricted jurisdictions and persons

  • YembiPay does not settle value to or from any territory subject to comprehensive sanctions under the sanctions regimes that bind the USD and stablecoin legs of a settlement, including the regimes administered by the United States Office of Foreign Assets Control, the United Nations, the United Kingdom, and the European Union.
  • YembiPay does not serve any person or entity that appears on a sanctions list it screens, or that is owned 50 percent or more, individually or in aggregate, by such persons. By onboarding, an organization represents that it is not so owned and agrees to notify YembiPay within 5 business days if that changes.
  • Corridors are risk-rated using regional and international assessments. Higher-rated corridors require enhanced due diligence and lower limits. Corridor availability is shown in the authenticated capability state.
  • Neighbouring territories under partial or sectoral sanctions are served only where the specific counterparty, sector, and purpose are permitted, and only after enhanced review.

Prohibited uses of the platform

  • Bypassing, disabling, or testing screening, limits, evidence requirements, or service restrictions without written permission.
  • Reusing another organization's idempotency keys or quote identifiers, or retrying a value-moving command without the original key and the current authoritative state.
  • Presenting a sandbox quote, settlement, or certificate as evidence of live compliance.
  • Submitting beneficiaries or business lines that were not disclosed at onboarding, or letting an undisclosed third party operate under your credentials.
  • Providing false or outdated organization, ownership, or contact information, or failing to notify a material change within 5 business days.
  • Scraping quotes to build a rate feed, or using the API in a way that degrades the service for others.

What happens on a violation

Depending on severity, YembiPay may hold or return affected settlements, lower limits, require additional evidence, suspend access, or end the relationship immediately under the Terms of Service. Where a report to a regulator or financial intelligence unit is required, it is made without notice to the organization. Decisions can be questioned through the Complaints process, except where law prohibits discussion.

Changes

This policy is revised independently of the Terms of Service so it can respond to issuer, rail, and regulatory changes. Registered organizations are notified of changes that could affect their approved activity.

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YembiPay is settlement software, not a bank. It holds no deposits, is not yet licensed in any jurisdiction, and live value movement remains gated.

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