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 Individuals
Last updated: April 23, 2025
This policy outlines the categories of individuals who are either prohibited from using the ZSD Platform by Zero Sum Defense, Inc. ("ZSD," "we," "us," or "our") or who 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 INDIVIDUAL OR TO TERMINATE ACCOUNTS AT OUR DISCRETION IF WE DETERMINE THAT AN INDIVIDUAL FALLS WITHIN A PROHIBITED CATEGORY OR HAS VIOLATED THE TERMS OF A RESTRICTION.
Policy Details
The following categories of individuals are prohibited from using the ZSD Platform:
1.1 Sanctioned Individuals
Individuals who 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 Individuals Engaged in Prohibited Activities
Individuals who are known to be engaged in:
- Terrorist activities or financing of terrorism
- Money laundering or financing of money laundering operations
- Human trafficking or exploitation
- Illegal arms trafficking
- Narcotics trafficking
- Cybercrime, including ransomware operations, hacking for hire, or operating botnets
- Creation or distribution of malware or other harmful code
- Identity theft or fraudulent activities
- Other illegal activities that could compromise the integrity, security, or reputation of the ZSD Platform
1.3 Individuals Subject to Legal Restrictions
Individuals who:
- Are subject to a court order prohibiting them from using security or encryption services
- Have been convicted of specific cyber crimes and are prohibited from using certain types of technology
- Are subject to regulatory actions that restrict their use of financial or security services
1.4 Other Prohibited Individuals
ZSD may also prohibit individuals who:
- 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
The following categories of individuals may use the ZSD Platform with specific restrictions or additional requirements:
2.1 Politically Exposed Persons (PEPs)
Individuals who are or have been entrusted with prominent public functions, their family members, or close associates. PEPs may use the ZSD Platform subject to:
- Enhanced due diligence during the onboarding process
- Ongoing monitoring of account activities
- Possible limitations on certain high-risk features
- Additional documentation requirements
2.2 Individuals in Certain High-Risk Jurisdictions
Individuals residing in or citizens of 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. These individuals may use the ZSD Platform subject to:
- Enhanced verification procedures
- Transaction limits or monitoring
- Restrictions on certain features or capabilities
- Periodic re-verification requirements
2.3 Individuals Under 18 Years of Age
Individuals who are at least 13 years old but under 18 years old may use the ZSD Platform only:
- With verifiable parental or legal guardian consent
- For limited, age-appropriate features and capabilities
- Without access to certain advanced security features
- With enhanced privacy protections
Children under 13 years of age are prohibited from using the ZSD Platform directly, in compliance with the Children’s Online Privacy Protection Act (COPPA) and similar regulations in other jurisdictions.
2.4 Individuals Subject to Specific Regulatory Requirements
Individuals in certain regulated professions or subject to specific regulatory oversight may use the ZSD Platform subject to:
- Compliance with applicable regulatory requirements
- Additional documentation or certifications
- Specific configurations to meet regulatory standards
- Enhanced audit trail requirements
3.1 Identity Verification. ZSD implements a risk-based approach to identity verification. Depending on the risk assessment, individuals may be required to provide:
- Basic personal information (name, email, etc.)
- Government-issued identification documents
- Proof of address
- Biometric verification
- Additional documentation for specific use cases
3.2 Screening. ZSD conducts screening against relevant sanctions lists, PEP databases, and other risk indicators. This screening may:
- Occur during the initial onboarding process
- Be repeated periodically throughout the customer relationship
- Be triggered by certain high-risk activities or changes in circumstances
3.3 Risk Assessment. ZSD conducts risk assessments to determine whether an individual falls into a prohibited or restricted category. These assessments consider:
- Geographic location
- Type of activity or intended use
- Relationship to other known high-risk individuals or entities
- Transaction patterns
- Other risk indicators
3.4 Compliance Updates. ZSD regularly updates its verification procedures to maintain compliance with applicable laws and regulations. Users may be required to provide updated information or undergo additional verification steps as regulations evolve or as their risk profile changes.
4.1 Account Termination. If ZSD determines that an individual falls within a prohibited category or has violated the terms of a restriction, we may:
- Immediately terminate the individual’s account
- Suspend access to all or part of the services
- Block future registration attempts
4.2 Data Handling. Upon account termination due to a prohibited status:
- User 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
4.3 Legal Consequences. Individuals who 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
4.4 Appeals. Individuals who 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
- Cooperating with any additional verification processes
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
- Data protection and privacy laws
- Age verification and protection requirements
5.2 Cooperation with Authorities. ZSD cooperates with legitimate requests from law enforcement and regulatory authorities regarding prohibited or restricted individuals, 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. Users will be notified of significant changes through the ZSD Platform or via email.
If you have any questions or concerns about this policy, please contact us at:
Zero Sum Defense, Inc.
Email: legal@zerosumdefense.co
Address: 7455 France Ave S, #277, Minneapolis, MN 55435
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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 Individuals Policy.
Last updated: April 23, 2025