Digital Capital Ltd
Digital Capital is currently pre-operational and does not provide live services or hold customer funds. Operational descriptions state the proposed requirements for a service once activated; they are not a certification that those arrangements are already implemented.
1.1 This Acceptable Use Policy (“AUP”) forms part of the Account and Payment Services Agreement.
1.2 It sets out the rules governing acceptable and prohibited use of our services.
1.3 This AUP is designed to:
protect customers
prevent financial crime
ensure compliance with applicable laws and regulations
manage operational and reputational risk
2.1 The initial AUP applies to accepted UK-established hospitality business customers and their authorised users. A sole trader is accepted only for business use. Personal consumer accounts are outside the initial product.
2.2 This policy applies to Digital Capital's e-money account and supported domestic GBP payment services and to your use of the Digital Capital interface for optional savings. A separate Griffin savings deposit remains subject to its own accepted terms.
2.3 Cards, consumer wallets, QR payments, loyalty services, card acquiring, international payments and FX are not part of the current package. Conditional references to future products do not authorise their use.
3.1 You must use our services:
lawfully
responsibly
in accordance with this Agreement
3.2 You must not use our services in a way that:
breaches laws or regulations
exposes us to risk
harms other users or the financial system
4.1 We apply a risk-based approach to acceptable use.
4.2 This means:
certain activities may be restricted or prohibited
restrictions may vary based on risk level
Prohibited use falls into the following categories:
5.1 Illegal activities
fraud
money laundering
terrorist financing
tax evasion
5.2 Financial crime and abuse
misuse of payment systems
account manipulation
circumvention of controls
5.3 Sanctions and regulatory breaches
dealing with sanctioned individuals or entities
transactions involving restricted jurisdictions
5.4 High-risk business activities
unlicensed financial services
fraudulent or deceptive schemes
5.5 Misuse of services
artificial transaction flows
abuse of refunds or chargebacks
6.1 This AUP should be read together with:
Account Agreement
Fraud Policy
7.1 We assess whether activity falls within the stated prohibitions using relevant facts, applicable law and the disclosed product boundaries, with proportionate review. Our discretion does not override mandatory rights or justify arbitrary treatment.
7.2 Our interpretation is based on:
applicable law
regulatory expectations
risk considerations
8.1 You are responsible for:
ensuring your use of services complies with this AUP
monitoring activity on your account
9.1 Breach of this AUP may result in:
suspension of services
account termination
reporting to authorities
9.2 Suspension, refusal and termination remain subject to the notification, review, redemption and termination protections in the Account Agreement. A breach allegation does not automatically cancel a refund or complaint right.
10.1 We may update this AUP periodically.
11.1 You must not use our services in connection with any activity that:
is unlawful
is fraudulent
exposes Digital Capital to regulatory, financial, or reputational risk
You must not use our services in connection with:
money laundering
terrorist financing
proliferation financing
tax evasion
sanctions evasion
Prohibited activities include:
impersonation scams
phishing schemes
identity theft
fraudulent investment schemes
deceptive sales practices
You must not:
artificially generate transactions
cycle funds to manipulate activity
misuse payment flows
attempt to bypass limits or controls
Prohibited activities include:
intentional chargeback abuse
false refund claims
repeated dispute misuse
manipulation of merchant disputes
15.1 Good-faith complaints, disputed transactions and statutory reimbursement requests are not abuse merely because a claim is rejected or inconvenient. We distinguish deliberate dishonesty from mistakes and additional support needs.
15.2 Using the pilot closure and tariff-refund promise in good faith is not misuse. No reason or proof of dissatisfaction is required. Exercising that promise does not waive a payment, complaint or other legal right.
You must not:
transact with sanctioned individuals or entities
use services in restricted jurisdictions
facilitate sanctioned transactions
16.1 This includes applicable ownership and control sanctions prohibitions and lawfully binding restrictions. The UK customer and domestic-route boundary applies separately from a connected person’s overseas residence. We apply proportionate enhanced checks for PEPs and their relatives or close associates and do not treat PEP status alone as a prohibited activity.
You must not use our services for:
unlicensed financial services
unauthorised payment services
illegal investment activity
18.1 The initial target market excludes gambling, cryptoasset exchange or custody, money service businesses, adult or sexual services, weapons, dealers in high-value precious metals or art, and investment or foreign-exchange schemes, whether or not a particular activity might be lawful in another context.
18.2 Counterfeit goods, pyramid and Ponzi schemes, fraudulent marketplaces and other illegal or deceptive activities remain prohibited. Non-hospitality activity outside the approved target market, concealed cash-to-account conversion and settlements for unrelated merchants are also excluded.
18.3 Enhanced due diligence cannot authorise a prohibited sector. A sector expansion requires a complete risk and product assessment and the relevant Board and provider approvals before any service is offered.
19.1 The initial service excludes cryptoasset exchange or custody businesses and cryptoasset payment routes.
19.2 Unregulated exchanges, high-risk token activity and attempts to disguise a cryptoasset business as hospitality must not use the initial product. Any future expansion requires prior product and financial-crime assessment and formal approval, not a customer-level exception.
20.1 Transactions involving certain merchant categories may be:
restricted
declined
You must not:
structure transactions to avoid limits
split transactions artificially
disguise transaction purpose
You must not:
allow unauthorised third parties to use your account
operate accounts on behalf of undisclosed parties
22.1 The initial service does not support shell banks, money-mule arrangements, unapproved payment intermediaries, undisclosed third-party client-money holding or collecting settlements for unrelated merchants. Ownership, control and payment purpose must be verifiable.
You must not:
provide false information
misrepresent identity or purpose
conceal beneficial ownership
You must not use our services in connection with:
illegal goods
controlled substances
counterfeit items
prohibited weapons
You must not use services for:
harmful activities
abusive or exploitative conduct
You must not:
attempt to interfere with systems
exploit vulnerabilities
disrupt services
You must not:
misuse personal data
breach data protection laws
process data unlawfully
We may restrict additional activities based on:
regulatory expectations
risk assessments
operational considerations
29.1 We monitor activity to ensure compliance with this AUP.
29.2 Monitoring may include:
transaction monitoring
behavioural analysis
risk scoring
fraud detection systems
29.3 Monitoring may be:
automated
manual
30.1 We apply controls based on risk.
30.2 These controls may include:
transaction limits
payment restrictions
additional verification
30.3 Controls may be applied dynamically.
31.1 Where a breach is suspected, we may:
investigate account activity
request information
review transactions
31.2 Investigations may involve third parties.
32.1 Where this AUP is breached, we may:
decline transactions
block payments
restrict account functionality
suspend services
terminate the account
32.2 Urgent lawful restrictions may be imposed without advance notice where the relevant conditions are met, but we provide required subsequent information and review. Permanent account closure follows the Account Agreement, including the applicable notice and reasons requirements.
33.1 We may suspend accounts where:
fraud is suspected
regulatory risk is identified
compliance concerns arise
33.2 During suspension:
transactions may be restricted
access may be limited
33.3 We may block a payment instrument for objectively justified reasons relating to its security or suspected unauthorised or fraudulent use, and take restrictions required by law. We will tell you of the block and reasons in the agreed manner before it, or immediately afterwards if advance notice is not possible, unless disclosure would compromise objectively justified security reasons or is unlawful. We will unblock it or replace it once the reasons cease. Account termination follows the separate termination provisions; a temporary block does not remove safeguarding, refund, redemption or complaint rights.
34.1 We may terminate accounts where:
breaches are serious or repeated
risk cannot be mitigated
34.2 For an indefinite framework contract entered into on or after 28 April 2026, ordinary termination by us will be on at least 90 days’ notice on a durable medium. The notice will state sufficiently detailed and specific reasons to enable you to understand the termination and give complaints and Financial Ombudsman Service information where applicable. Shorter notice, immediate termination or withholding information is permitted only to the extent a specific statutory exception in regulations 51C or 51D applies, or another applicable law requires it. A generic reference to risk, a scheme change or breach of contract is not itself such an exception. We will consider the applicable grounds and information duties individually. An ongoing investigation does not create an unlimited right to withhold your balance.
35.1 We may report activity to:
regulators
law enforcement
35.2 This may occur without prior notice where required by law.
36.1 Where services are accessed via a Partner:
we retain responsibility for regulated services
we retain enforcement authority
36.2 Partner access does not limit our ability to:
monitor
restrict
terminate
37.1 Enforcement actions may impact:
payments
account access
38.1 We give notice and reasons in the manner and time required for the action taken, including refusal, instrument blocking or termination; these are distinct processes with distinct legal duties.
38.2 We withhold information only to the extent an applicable legal or specifically permitted security exception allows. A general reference to an investigation does not remove all notice duties.
39.1 You may contact us if you believe enforcement action was taken incorrectly.
39.2 We review a challenge fairly, explain the outcome where lawful and provide the Complaints Policy and applicable FOS route. Support needs and verified representative authority are considered.
40.1 This AUP operates alongside:
Fraud Policy
Account Agreement
41.1 We may update controls and restrictions based on:
emerging risks
regulatory changes
operational experience
42.1 This AUP is reviewed periodically.
42.2 For a change to the framework agreement or an agreed fee or limit requiring notice, we will give at least two months’ advance notice on a durable medium, explain the proposed change, and tell you that you may reject it and terminate without charge before it takes effect. Where the notice expressly provides for deemed acceptance, you are treated as accepting only if you do not reject it before that date. Publishing a revised webpage alone is insufficient. Any immediate change must fall within a specific legal permission, such as an agreed reference exchange-rate mechanism or a change more favourable to you; urgent security controls are governed by the separate blocking provisions.