Prohibited Transactions Policy

1. Scope

1.1 This Prohibited Transactions Policy (the "Policy") describes transactions, goods, services, jurisdictions, and persons that are not permitted on the Escrow Bunny platform (the "Platform" or "Service").

1.2 This Policy applies to all Users, Organizations, beneficial owners, and Escrows and is incorporated by reference into the Terms of Service and the Standard Escrow Agreement. It is read together with the KYC/KYB and Sanctions Screening Policy, the Funds Release and Refund Authorization Policy, and the Dispute Resolution Policy.

1.3 In the event of conflict, the [order of precedence in the Terms of Service Section 1.3 / Standard Escrow Agreement Section 1.4 controls — PLACEHOLDER pending counsel confirmation].

1.4 Capitalized terms not defined here have the meaning given in the Terms of Service and the Standard Escrow Agreement.

2. Definitions

• "Prohibited Transaction" — any transaction, or any use of the Service, that falls within a category in this Policy or is otherwise prohibited by the Terms of Service, the Policies, or applicable law.
• "Prohibited Goods/Services" — goods or services within a prohibited category in Section 4.
• "Prohibited Jurisdiction" — a country, region, or territory designated as prohibited under Section 5.
• "Prohibited Person" — a person or entity that may not use the Service under Section 6.
• "Restricted" — permitted only subject to additional conditions, review, or approval. [Confirm whether a "restricted" tier exists or whether all listed categories are outright prohibited.]
• Other capitalized terms have the meaning given in the Terms of Service and the Standard Escrow Agreement.

3. General Prohibition

3.1 You must not use the Service for any unlawful purpose or for any Prohibited Transaction, and must not facilitate, attempt, structure, disguise, or assist another person in doing so.

3.2 You must not use the Service in a manner that violates applicable anti-money-laundering, counter-terrorist-financing, sanctions, export-control, fraud, consumer-protection, intellectual-property, tax, or other laws.

3.3 You must not provide false, misleading, or unauthorized information or documents to evade this Policy or any verification or screening control.

4. Prohibited Goods, Services, and Activities (Indicative List)

The following is an indicative starting list for counsel to finalize. It is not exhaustive and not a legal determination. Counsel must confirm the controlling categories per jurisdiction and reconcile with the applicable regulatory framework, sanctions/export-control regimes, and provider/processor restrictions.

4.1 Illegal goods or services, or transactions that are unlawful in any applicable jurisdiction.

4.2 Controlled or regulated categories that Escrow Bunny does not support, which may include (subject to counsel finalization): controlled substances and related paraphernalia; weapons, ammunition, explosives, and related items; counterfeit, pirated, or infringing goods; stolen goods; human or wildlife exploitation or trafficking; child sexual abuse material and any child exploitation (strictly prohibited); and other categories counsel designates.

4.3 Financial-crime and evasion activities, including money laundering, terrorist financing, sanctions evasion, fraud, Ponzi/pyramid or other unlawful schemes, and transactions designed to disguise the source, ownership, or destination of funds.

4.4 Excluded financial/product categories inconsistent with the Platform's design, including cryptocurrency/virtual-asset transactions, blockchain-settled transactions, smart-contract-based arrangements, yield- or interest-bearing arrangements, and investment/securities-type products — the Platform does not support these.

4.5 Regulated activities Escrow Bunny is not authorized or designed to facilitate, including (subject to counsel finalization) money transmission outside the Platform's intended design, securities/investment offerings, gambling, regulated financial services, and similar activities. [Counsel to finalize; depends on the escrow-role and regulatory determinations in the Terms of Service / Standard Escrow Agreement / KYC-KYB Policy.]

4.6 High-risk or restricted categories that may be prohibited or restricted pending review, including [PLACEHOLDER — counsel to enumerate, e.g., adult content, certain professional services, high-value/identifiable assets requiring special handling, or other categories per risk and provider restrictions].

4.7 Provider-restricted categories. Categories prohibited or restricted by Escrow Bunny's third-party providers (including any future payment processor, Verified by Toni, or infrastructure providers). [Confirm provider acceptable-use restrictions and incorporate.]

4.8 Any other transaction Escrow Bunny determines, in its reasonable discretion, presents unacceptable legal, financial-crime, fraud, reputational, or operational risk. [Confirm scope of discretion and any consumer-law limits with counsel.]

5. Prohibited Jurisdictions

5.1 The Service may not be used by, for, or in connection with persons located in, ordinarily resident in, or organized under the laws of a Prohibited Jurisdiction, or for transactions connected to a Prohibited Jurisdiction.

5.2 [CRITICAL PLACEHOLDER — counsel must determine the controlling list of Prohibited Jurisdictions (e.g., comprehensively sanctioned or embargoed territories and any additional jurisdictions excluded for risk or licensing reasons), per the applicable sanctions/export-control regimes and the KYC/KYB and Sanctions Screening Policy. Do not assert a list until confirmed. The list must be maintained and updated.]

5.3 Geographic restrictions are enforced through verification, screening, and other controls. Attempts to circumvent geographic restrictions (e.g., misrepresentation of location, use of intermediaries) are prohibited.

6. Prohibited Persons

6.1 The Service may not be used by:

• any person on an applicable sanctions, denied-party, or restricted-party list, or owned/controlled by, or acting for, such a person;
• any person who fails or evades required identity, organization, or beneficial-owner verification or screening;
• any person barred under the Terms of Service or by applicable law; or
• [other categories — PLACEHOLDER; counsel to confirm, e.g., persons in Prohibited Jurisdictions, persons previously offboarded for cause, or persons below the eligibility age].

6.2 Screening and ongoing monitoring for Prohibited Persons are conducted under the KYC/KYB and Sanctions Screening Policy.

7. Detection, Enforcement, and Consequences

7.1 Escrow Bunny may use verification, screening, monitoring, and review to detect actual or suspected Prohibited Transactions, Goods/Services, Jurisdictions, or Persons.

7.2 Where a Prohibited Transaction (or reasonable suspicion of one) is identified, Escrow Bunny may, as permitted by law and the Policies:

• decline to create or fund an Escrow;
• freeze or hold an Escrow, Release, or Refund (see Funds Release and Refund Authorization Policy);
• suspend, restrict, or offboard an Account or Organization;
• request additional information or documentation;
• reverse or unwind, or decline to process, a transaction; and/or
• take any action required by law or legal process.

7.3 [Counsel to determine any legal/regulatory reporting obligations (e.g., suspicious-activity or sanctions reporting) and any prohibition on disclosing the reason for an action (anti-tipping-off). User-facing messaging must not conflict with mandatory disclosure restrictions. Do not assert reporting conclusions until confirmed.]

7.4 Consequences of breach may include loss of access, forfeiture of fees (as permitted), liability for resulting losses, and referral to authorities where required or permitted by law. Nothing limits other remedies available to Escrow Bunny under the Terms of Service or applicable law.

7.5 Handling of funds associated with a Prohibited Transaction (including whether they are held, returned, or dealt with as legally required) is governed by the Funds Release and Refund Authorization Policy and applicable law. [Counsel to confirm, including any obligation or restriction on returning funds to a sanctioned or prohibited party.]

8. User Obligations and Representations

8.1 Each User and Organization represents and warrants, on an ongoing basis, that:

• its use of the Service and each Escrow is lawful and not a Prohibited Transaction;
• it is not a Prohibited Person and is not located in or connected to a Prohibited Jurisdiction;
• the goods/services and the underlying transaction are not within a prohibited category;
• funds and assets are from lawful sources; and
• it is not acting for an undisclosed Prohibited Person or to evade this Policy or applicable law.

8.2 Each User and Organization must promptly notify Escrow Bunny if it becomes aware that an Escrow may involve a Prohibited Transaction, and must not proceed with such an Escrow.

9. Changes to This Policy

9.1 Escrow Bunny may update this Policy, including the prohibited and restricted categories and jurisdictions, at any time, particularly to reflect legal, regulatory, sanctions, or provider changes. Material changes are notified by [notice method — PLACEHOLDER] with a stated effective date; the version and effective date are recorded, and acceptance is captured by document type and exact version where required. Updates to sanctions/jurisdiction lists may take effect immediately where required by law.

10. User Acknowledgements

By using the Service, each User and Organization acknowledges and agrees that:

• It will not use the Service for any Prohibited Transaction or with Prohibited Goods/Services, Prohibited Jurisdictions, or Prohibited Persons.
• The listed categories are indicative and may be updated, and Escrow Bunny may decline or unwind transactions presenting unacceptable risk.
• Escrow Bunny may decline, freeze, hold, suspend, offboard, reverse, or report as described, and certain disclosures may be legally restricted.
• It makes the ongoing representations in Section 8 and will notify Escrow Bunny of any suspected Prohibited Transaction.
• Breach may result in loss of access, fee forfeiture (as permitted), liability, and referral to authorities.

Acceptance capture: Acceptance of this Policy is recorded by document type and exact version, with associated User, timestamp, IP address, and user agent.

11. Contact / Legal Notice

• Operating entity: [LEGAL ENTITY NAME — PLACEHOLDER]
• Registered address: [ADDRESS — PLACEHOLDER]
• Compliance contact: [COMPLIANCE EMAIL — PLACEHOLDER]
• Report a concern: [REPORTING CHANNEL — PLACEHOLDER]
• Legal notices: [LEGAL NOTICE EMAIL / POSTAL ADDRESS — PLACEHOLDER; see Support, Complaints, and Legal Notices Policy]

12. Change History