Legal Agreements
Explore the legal terms and agreements that govern the use of Actualize by Zero Sum Defense, supporting transparency and trust in our services.
ZSD Prohibited and Restricted Entities
Last updated: April 23, 2025
This policy outlines the categories of entities that are either prohibited from using the ZSD Platform by Zero Sum Defense, Inc. ("ZSD," "we," "us," or "our") or that may use our services with certain restrictions. This policy is part of and incorporated into our ZSD Services Agreement.
ZSD RESERVES THE RIGHT TO DENY SERVICE TO ANY ENTITY OR TO TERMINATE ACCOUNTS AT OUR DISCRETION IF WE DETERMINE THAT AN ENTITY FALLS WITHIN A PROHIBITED CATEGORY OR HAS VIOLATED THE TERMS OF A RESTRICTION.
Policy Details
The following categories of entities are prohibited from using the ZSD Platform:
1.1 Sanctioned Entities
Entities that appear on government sanctions lists, including but not limited to:
- The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List
- UN Security Council Consolidated List
- EU Consolidated Financial Sanctions List
- UK HM Treasury Consolidated List of Financial Sanctions Targets
- Other applicable sanctions lists maintained by jurisdictions in which ZSD operates
1.2 Entities in Embargoed Countries or Regions
Entities located, incorporated, or primarily operating in countries or regions subject to comprehensive international sanctions or embargoes, including but not limited to North Korea, Iran, Syria, Cuba, and the Crimea, Donetsk, and Luhansk regions.
1.3 Entities Engaged in Prohibited Activities
Entities that are known to be primarily engaged in:
- Terrorist activities or financing of terrorism
- Money laundering or operation of money laundering schemes
- Human trafficking or exploitation
- Illegal arms trafficking
- Narcotics trafficking
- Production, distribution, or promotion of child sexual abuse material (CSAM)
- Ransomware operations, cyber extortion, or malicious hacking services
- Creation or distribution of malware or other harmful code
- Identity theft or fraudulent activities
- Promotion of violence or hate speech targeting protected groups
- Operation of Ponzi schemes or other illegal financial operations
1.4 Entities Subject to Legal Restrictions
Entities that:
- Are subject to a court order prohibiting them from using security or encryption services
- Have directors, officers, or controlling shareholders who are prohibited from using our services under our Prohibited Individuals policy
- Are subject to regulatory actions that restrict their use of financial or security services
- Have been found liable for specific cyber crimes or data breaches and are prohibited from using certain types of technology
1.5 Other Prohibited Entities
ZSD may also prohibit entities that:
- Have previously violated our Terms of Service in a significant manner
- Have attempted to circumvent our security or verification processes
- Have used our services to harm others or to facilitate harmful activities
- Present a significant risk to the security, stability, or compliance of our platform
- Have engaged in fraudulent activities or misrepresentation in their dealings with us
The following categories of entities may use the ZSD Platform with specific restrictions or additional requirements:
2.1 Financial Institutions
Financial institutions, including banks, credit unions, payment processors, and money services businesses, may use the ZSD Platform subject to:
- Enhanced due diligence during the onboarding process
- Verification of appropriate regulatory licenses and registrations
- Implementation of specific security configurations and controls
- Regular compliance attestations
- Additional contractual terms relating to regulatory compliance
2.2 Entities in High-Risk Industries
Entities operating in industries with elevated risk profiles, including but not limited to:
- Cryptocurrency exchanges and wallet providers
- Online gambling and gaming companies
- Adult entertainment businesses
- Private military contractors
- Precious metals and gemstone dealers
These entities may use the ZSD Platform subject to:
- Enhanced verification procedures
- Industry-specific compliance certifications
- Additional monitoring and periodic reviews
- Limitations on certain features or usage patterns
- Additional documentation requirements
2.3 Entities in Certain Jurisdictions
Entities located or primarily operating in jurisdictions identified as high-risk for money laundering, terrorism financing, or other financial crimes by the Financial Action Task Force (FATF) or other relevant authorities may use the ZSD Platform subject to:
- Enhanced due diligence on the entity, its directors, and beneficial owners
- Additional documentation regarding the entity’s operations and funding sources
- Restrictions on transaction volumes or certain functionalities
- Periodic re-verification requirements
2.4 Entities Subject to Specific Regulatory Requirements
Entities in regulated industries, such as healthcare, education, or critical infrastructure, may use the ZSD Platform subject to:
- Compliance with applicable regulatory requirements (e.g., HIPAA, FERPA, NERC CIP)
- Implementation of specific security controls required by their industry regulations
- Additional data protection measures appropriate to their industry
- Regular compliance attestations or certifications
- Execution of industry-specific addenda to our standard agreements
2.5 Government Entities
Government agencies, departments, and other public sector entities may use the ZSD Platform subject to:
- Verification of their official status and authority
- Compliance with applicable procurement and contracting regulations
- Specialized terms regarding data sovereignty and legal jurisdiction
- Additional security measures as required by government standards (e.g., FedRAMP, IL2/IL4/IL5)
3.1 Entity Verification. ZSD implements a risk-based approach to entity verification. Depending on the risk assessment, entities may be required to provide:
- Entity registration documents (e.g., certificates of incorporation, business licenses)
- Proof of address and location of operations
- Identification of directors, officers, and beneficial owners
- Industry-specific licenses or certifications
- Evidence of compliance with applicable regulations
- Financial statements or banking references
3.2 Screening. ZSD conducts screening against relevant sanctions lists, adverse media, and other risk indicators. This screening may:
- Occur during the initial onboarding process
- Be repeated periodically throughout the business relationship
- Be triggered by certain high-risk activities or changes in circumstances
- Include screening of associated individuals (directors, officers, beneficial owners)
3.3 Risk Assessment. ZSD conducts risk assessments to determine whether an entity falls into a prohibited or restricted category. These assessments consider:
- Geographic location and jurisdiction
- Industry and business activities
- Ownership and management structure
- Regulatory status and compliance history
- Transaction patterns and usage profiles
- Relationship to other known high-risk entities or individuals
3.4 Enhanced Due Diligence. For entities identified as higher risk or falling into a restricted category, ZSD may conduct enhanced due diligence, which may include:
- More extensive verification of ownership and control
- Verification of source of funds
- Reviews of compliance programs and policies
- Background checks on key personnel
- Interviews with company representatives
3.5 Ongoing Monitoring. ZSD maintains ongoing monitoring of entities to detect changes that may affect their eligibility to use our services. This includes:
- Regular rescreening against sanctions lists
- Monitoring for adverse media or regulatory actions
- Periodic review of high-risk entities
- Transaction monitoring for suspicious activities
4.1 Account Termination. If ZSD determines that an entity falls within a prohibited category or has violated the terms of a restriction, we may:
- Immediately terminate the entity’s account
- Suspend access to all or part of the services
- Block future registration attempts
- Implement restrictions on affiliated entities or individuals
4.2 Data Handling. Upon account termination due to a prohibited status:
- Entity data will be handled in accordance with our Privacy Policy and applicable laws
- Some data may be retained for compliance with legal obligations
- Data may be provided to law enforcement or regulatory authorities as required by law
- Funds or assets may be frozen or returned according to applicable regulations
4.3 Legal Consequences. Entities that knowingly violate this policy may also face:
- Legal action by ZSD for breach of contract
- Reporting to relevant regulatory or law enforcement authorities
- Liability for damages caused to ZSD or other users
- Placement on internal blocklists for future services
4.4 Appeals. Entities that believe they have been incorrectly identified as prohibited or restricted may appeal the determination by:
- Submitting a written appeal to legal@zerosumdefense.co
- Providing additional documentation or information to support their appeal
- Engaging with any additional verification processes we may require
- Demonstrating remediation of any identified issues
5.1 Regulatory Framework. This policy is designed to comply with applicable laws and regulations, including:
- Anti-money laundering (AML) laws and regulations
- Counter-terrorist financing (CTF) laws and regulations
- Economic and trade sanctions programs
- Export control regulations
- Data protection and privacy laws
- Industry-specific regulations applicable to our services
5.2 Cooperation with Authorities. ZSD cooperates with legitimate requests from law enforcement and regulatory authorities regarding prohibited or restricted entities, subject to applicable laws and our Privacy Policy.
5.3 Policy Updates. ZSD may update this policy from time to time to reflect changes in applicable laws, regulations, or best practices. Entities will be notified of significant changes through the ZSD Platform or via email.
5.4 Contractual Obligations. Entities are contractually obligated to:
- Provide accurate and complete information during the onboarding process
- Promptly notify ZSD of any changes that may affect their eligibility status
- Comply with all applicable laws and regulations in their use of our services
- Adhere to any specific restrictions or requirements communicated by ZSD
6.1 Humanitarian Exemptions. In limited circumstances, ZSD may grant exemptions to certain restrictions for entities engaged in legitimate humanitarian activities, provided that:
- The entity provides documentation of any applicable humanitarian exemptions granted by relevant authorities
- The entity implements enhanced controls to prevent misuse of our services
- The exemption is reviewed and approved by our compliance committee
- The entity agrees to enhanced monitoring and reporting requirements
6.2 Exceptions for Legal or Regulatory Compliance. ZSD may grant exceptions when necessary to comply with applicable laws or regulations, such as:
- When denying service would violate anti-discrimination laws
- When access is required by a valid court order or other legal mandate
- When specific regulatory frameworks require the provision of basic services
6.3 Tailored Restrictions. In some cases, rather than completely prohibiting an entity from using our services, ZSD may implement tailored restrictions that address specific risk concerns while allowing limited use of the services.
If you have any questions or concerns about this policy, please contact us at:
Zero Sum Defense, Inc.
Email: security@zerosumdefense.co
Address: 7455 France Ave S, #277, Minneapolis, MN 55435
Explore Related Legal Information
By using the ZSD Platform, you acknowledge that you have read, understood, and agree to be bound by the terms of this Prohibited and Restricted Entities Policy.
Last updated: April 23, 2025