Legal

As a global financial institution, OMEN® is committed to full compliance with all applicable laws and regulations regarding Anti- Money Laundering (“AML”). OMEN®’s policy is to prevent people engaged in money laundering, fraud, and other financial crimes, including terrorist financing, from using OMEN®’s services.

OMEN® has robust policies and procedures to detect, prevent and report suspicious activity. To comply with OFAC (Office of Foreign Asset Control) requirements, and global sanctions, we screen our customer accounts against government watch lists. In addition, we may request that you provide us with documentation to help prove your identity or for business verification purposes. We report suspicious transactions to the financial intelligence unit in the respective country.

How does this impact me?

As part of our AML procedures, we collect information from you to satisfy our Know Your Customer requirements. This means that we may request information from you due to a specific identification requirement or as a result of our watch list screening process. We may ask you to provide documentation to help confirm your identity or provide additional information regarding your business. We may also request that you seek pre-approval for utilizing the OMEN® service if your account falls within a high-risk compliance category, as listed in our Acceptable Use Policy (AUP);

You are independently responsible for complying with all applicable laws in all of your actions related to your use of OMEN®’s services, regardless of the purpose of the use. In addition, you must adhere to the terms of this Acceptable Use Policy.

Prohibited Activities

You may not use the OMEN® service for activities that:
1. violate any law, statute, ordinance or regulation
2. relate to sales of (a) narcotics, steroids, certain controlled substances or other products that present a risk to consumer safety, (b) drug paraphernalia, (c) items that encourage, promote, facilitate or instruct others to engage in illegal activity, (d) items that promote hate, violence, racial intolerance, or the financial exploitation of a crime, (e) items that are considered obscene, (f) items that infringe or violate any copyright, trademark, right of publicity or privacy or any other proprietary right under the laws of any jurisdiction, (g) certain sexually oriented materials or services, or (h) ammunition, firearms, or certain firearm parts or accessories, or (i) ,certain weapons or knives regulated under applicable law
3. relate to transactions that (a) show the personal information of third parties in violation of applicable law, (b) support pyramid or ponzi schemes, matrix programs, other “get rich quick” schemes or certain multi-level marketing programs, (c) are associated with purchases of real property, annuities or lottery contracts, lay-away systems, off-shore banking or transactions to finance or refinance debts funded by a credit card, (d) are for the sale of certain items before the seller has control or possession of the item, (e) are by payment processors to collect payments on behalf of merchants, (f), are associated with the following Money Service Business activities: the sale of traveler’s checks or money orders, currency exchanges or check cashing,or (g) provide certain credit repair or debt settlement services
4. involve the sales of products or services identified by government agencies to have a high likelihood of being fraudulent
5. violate applicable laws or industry regulations regarding the sale of (a) tobacco products, or (b) prescription drugs and devices
6. involve gambling, gaming and/or any other activity with an entry fee and a prize, including, but not limited to casino games, sports betting, horse or greyhound racing, lottery tickets, other ventures that facilitate gambling, games of skill (whether or not it is legally defined as a lottery) and sweepstakes unless the operator has obtained prior approval from OMEN® and the operator and customers are located exclusively in jurisdictions where such activities are permitted by law.

Activities Requiring Approval

OMEN® requires pre-approval to accept payments for certain services as set out in 6 above and detailed in the chart below.

When using OMEN®’s services in support of eBay transactions, you must comply with all of these guidelines and eBay’s Prohibited and Restricted Items rules found here – http://pages.ebay.com/help/policies/items-ov.html.

Violations of the Acceptable Use Policy:
We encourage you to report violations of this Acceptable Use Policy to OMEN® immediately. If you have a question about whether a type of transaction may violate the Acceptable Use Policy, you can email OMEN®’s AUP Compliance Department at: aupviolations@odegardmedia.com.

Policy Terms Updated: September 8th, 2010