Restrictions
Business types we do not onboard
We publish this list up front: it is better to learn about a restriction before applying than to spend time on an application that has to be declined.
Why the list is public
These restrictions follow from anti-money-laundering and counter-terrorist-financing law, from payment system rules and from the requirements of participating banks — not from our discretion. Stating them up front is cheaper for both sides than a refusal at the last stage of the review.
We do not onboard
Gambling, betting and lotteries
Casinos, bookmakers, betting pools, online games played for money, sale of lottery tickets.
Cryptocurrency operations
Exchange, purchase and sale of virtual assets, exchange services, wallets, mining services, token sales.
Forex, binary options and margin trading
Dealing platforms, trading signals, asset management and any scheme promising income from trading.
Adult content
Erotic and pornographic material, dating services with paid intimate content, escort services.
Weapons, ammunition and their components
Firearms, traumatic and bladed weapons, cartridges, explosives and parts for them.
Narcotic drugs and psychotropic substances
Drugs, precursors, smoking blends, their analogues and any goods whose circulation is restricted or prohibited.
Counterfeit goods and infringement of intellectual property
Counterfeits, replicas, unlicensed software, activation keys, access to someone else’s paid content.
Financial pyramids and get-rich-quick schemes
Raising funds paid out of new participants’ money, multi-level networks earning on recruitment, “investment” projects that do not disclose where returns come from.
Trade in personal data
Selling databases, people-lookup services, collecting and reselling personal data without a lawful basis.
Activity without a required licence or permit
Activities for which Kyrgyz law requires a licence, permit or notification that the applicant does not hold.
The list is not exhaustive
It describes categories, not particular businesses. The final decision is made after the application is reviewed: we look at what the business actually does, not at what it is called. A refusal is also possible for an activity not named above — for example, if it falls under a participating bank’s restrictions or requires a permit the applicant does not hold.
If a restriction surfaces after onboarding
Payment acceptance for that line of business is suspended, documents are requested, and the case is handled under the procedure described in the AML/CFT section. This is why it is worth describing the real nature of the business in the application: a mismatch found later stops the service.
If your application is declined
A refusal is not a judgement about your business and is never published. You can ask for the reason and re-apply with additional documents through the compliance function.
Compliance contact: compliance@montra.kg
Related pages
AML/CFT and supervision · Security · Enquiries, claims and disputes · How to get connected