1. Purpose and Scope 目的及範圍
UnionRay Global Co. Limited (“UnionRay”, “we”, “us”) is a Hong Kong licensed Money Service Operator (MSO Licence No. 24-09-03245) providing cross-border Business-to-Consumer (B2C) Payment Collection services to corporate e-merchants. This Prohibited Products and Services Policy forms an integral part of the Merchant Service Agreement and applies to every merchant that uses UnionRay’s services.
This Policy sets out:
- The categories of products and services that merchants are strictly prohibited from selling, advertising or processing payments for through UnionRay’s platform;
- The legal basis for the prohibitions under Hong Kong law and international sanctions regimes;
- The controls UnionRay applies to detect, prevent and enforce compliance with this Policy;
- The consequences of breach, including account suspension, termination and regulatory reporting.
2. Legal Basis 法律依據
UnionRay’s prohibition framework is built on the following legal and regulatory sources:
- Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) and Schedule 2 thereunder;
- United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575) and related UNSC sanctions resolutions;
- United Nations Sanctions Ordinance (Cap. 537) and regulations made thereunder, including sanctions targeting the Democratic People’s Republic of Korea and Iran;
- Weapons of Mass Destruction (Control of Provision of Services) Ordinance (Cap. 526);
- Organized and Serious Crimes Ordinance (Cap. 455) and Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405);
- Export control and sanctions programmes administered by the United States (OFAC, BIS), European Union, United Kingdom (OFSI), United Nations, and the People’s Republic of China;
- Hong Kong Customs and Excise Department guidance and notices issued to MSOs.
3. Prohibited Categories 禁止類別
The following categories of products and services are strictly prohibited. A merchant must not use UnionRay’s B2C Payment Collection Service, directly or indirectly, in connection with any of them.n
| Category | Examples (non-exhaustive) |
|---|---|
| Illegal Drugs and Controlled Substances | Narcotics, cannabis, synthetic cannabinoids, cocaine, heroin, methamphetamine, precursor chemicals, unlicensed pharmaceuticals, prescription medicines sold without valid authorisation, and drug paraphernalia. |
| Weapons and Military Goods | Firearms, ammunition, explosives, military-grade equipment, dual-use goods subject to export controls, chemical/biological agents, and any items restricted under the Weapons of Mass Destruction (Control of Provision of Services) Ordinance. |
| Gambling and Betting | Online casinos, sports betting, lottery tickets (unless expressly authorised by the relevant jurisdiction), poker rooms, virtual gambling chips, and any unlicensed wagering activity. |
| Adult and Sexually Oriented Services | Pornography, escort services, prostitution, sexually oriented massage, adult webcam services, and products marketed for sexual exploitation. |
| Counterfeit and Pirated Goods | Fake branded goods, counterfeit currency, forged documents, pirated software, music, films, and any goods infringing intellectual-property rights. |
| Sanctions-Related Trade | Any transaction involving sanctioned persons, entities, countries or jurisdictions (including but not limited to OFAC SDN, UN, EU, UK, China and Hong Kong sanctions lists); goods or services originating from or destined to comprehensively sanctioned jurisdictions; and any activity intended to evade sanctions. |
| Unlicensed Financial Services | Money changing, remittance, payment services, stored-value facilities, virtual-currency exchange, ICOs, unlicensed lending, and any other financial service requiring a licence that the provider does not hold. |
| Money Laundering and Terrorist Financing Vehicles | Shell companies, nominee arrangements, Ponzi schemes, pyramid selling, multi-level marketing schemes with no genuine product, and any business model designed primarily to move or obscure funds. |
| Human Trafficking and Exploitation | Services involving forced labour, child exploitation, organ trafficking, and any form of modern slavery. |
| Stolen or Illegally Sourced Property | Goods known or suspected to be stolen, smuggled, or representing the proceeds of crime. |
| Deceptive or Fraudulent Products | Products making false health claims, miracle cures, unapproved medical devices, and goods marketed through misleading or fraudulent practices. |
| Wildlife and Environmental Contraband | Endangered-species products (e.g. ivory, rhino horn, pangolin scales), illegal timber, ozone-depleting substances, and hazardous waste. |
4. High-Risk Categories Requiring Pre-Approval 高風險類別（需預先審批）
Even if not outright prohibited, the following categories are considered high risk and will only be accepted after Enhanced Due Diligence (EDD), senior-management approval and, where required, additional documentation:
- Luxury goods, precious metals, jewellery and watches;
- Antiques, artwork and collectibles;
- Electronic devices with high resale value and rapid turnover;
- Dietary supplements, cosmetics and skincare products with cross-border claims;
- Travel, ticketing and event services;
- Digital goods, software licences and online subscriptions;
- Any business connected to a Politically Exposed Person (PEP).
5. Controls and Enforcement 管控及執行措施
5.1 Onboarding Controls
- Business nature declaration: Every merchant must declare its exact product/service categories, target markets and sales channels.
- Website / app review: UnionRay reviews the merchant’s public-facing platform to confirm consistency with the declared business and to detect prohibited content.
- EDD for high-risk merchants: Enhanced Due Diligence is applied to merchants in high-risk categories, including source-of-funds/source-of-wealth verification and senior-management approval.
- Six-dimension risk scoring: The Customer dimension of the risk-scoring model automatically assigns a reject score to prohibited industries and a high-risk score to high-risk industries.
5.2 Ongoing Monitoring
- Periodic re-review: Merchants are re-reviewed every 2 years (low risk), 1 year (medium risk) or 6 months (high risk).
- Transaction monitoring: UnionRay monitors for keywords, product descriptors and transaction patterns associated with prohibited categories.
- Adverse media and sanctions screening: Daily screening of the merchant and its connected parties against sanctions, PEP and adverse-media databases.
- Merchant portal audit: UnionRay may request updated product catalogues, marketing materials and sample invoices at any time.
5.3 Breach Response
If UnionRay reasonably suspects that a merchant is offering prohibited products or services, it may, without prior notice:
- Suspend settlement of funds to the merchant’s account;
- Freeze the account pending investigation;
- Terminate the Merchant Service Agreement immediately;
- File a Suspicious Transaction Report (STR) with the Joint Financial Intelligence Unit (JFIU);
- Notify the Hong Kong Customs and Excise Department and any other competent authority as required by law.
6. Merchant’s Undertaking 商戶承諾
By using UnionRay’s services, each merchant undertakes that:
- It will not sell, advertise, facilitate or process payments for any prohibited product or service listed in Section 3;
- It will not engage in any transaction involving sanctioned persons, entities, countries or jurisdictions;
- It will promptly notify UnionRay if it becomes aware of any actual or attempted breach of this Policy;
- It will cooperate fully with any investigation conducted by UnionRay or a competent authority;
- It accepts that UnionRay’s determination of a breach is binding for the purpose of suspending or terminating services.
7. Buyer-Facing Disclosure 買方披露
Merchants must ensure that their platforms do not misrepresent UnionRay as the seller of the underlying goods or services. Merchants must also clearly display their own return, refund and prohibited-products policies to Buyers. UnionRay is solely the merchant’s payment collection and settlement service provider and is not responsible for the merchant’s compliance with product-safety, consumer-protection or import/export laws.
8. Amendments 修訂
UnionRay may update this Policy from time to time to reflect changes in law, regulation, sanctions lists or risk appetite. Material changes will be notified to merchants by email or through the merchant portal at least thirty (30) days before taking effect. Continued use of the Service after the effective date constitutes acceptance of the amended Policy.
9. Contact 聯絡方式
UnionRay Global Co. Limited
Unit 03, 7/F., LT Tower, No. 31 Chong Yip Street, Kwun Tong, Kowloon, Hong Kong
MSO Licence No. 24-09-03245
Compliance / AML Enquiries: compliance@unionrayintl.com