Effective Date: 01 January 2025

Version: 1.0

This Acceptable Use Policy (“AUP”) outlines prohibited and restricted activities when using the Duzo platform. It forms part of the Duzo Terms of Service and applies to all users, including individuals and merchants.

Duzo is a service provided by Zen Capital (Pty) Ltd, a licensed Financial Services Provider (FSP No. 54453). This Policy reflects our commitment to lawful, responsible financial services and aligns with applicable legislation, including our internal Risk Management and Compliance Programme (RMCP).

1. Definitions

For purposes of this Policy:

1.1 “Account” means a registered user or merchant profile on the Duzo platform.

1.2 “Duzo” refers to the platform operated by Zen Capital (Pty) Ltd.

1.3 “FATF” refers to the Financial Action Task Force.

1.4 “FICA” means the Financial Intelligence Centre Act, 2001 (South Africa).

1.5 “High-Risk Jurisdiction” means any country or territory listed by the FATF or sanctioned by the United Nations or FSCA.

1.6 “Merchant” means a legal entity using Duzo to accept or convert digital assets.

1.7 “Mixer” or “Tumbler” means any service or software that obscures the origin of cryptocurrency.

1.8 “PEP” means a Politically Exposed Person, as defined under FICA.

1.9 “Platform” means the Duzo website, mobile application, or associated services.

1.10 “Sanctions List” includes designations from the United Nations, FATF, OFAC, or other recognised bodies.

1.11 “User” or “You” means any person or entity accessing or using Duzo’s services.

2. General Prohibited Uses

2.1 You may not use the Duzo platform for any purpose that is illegal, abusive, deceptive, or inconsistent with financial regulation.

2.2 Prohibited conduct includes, but is not limited to:

• Fraud, identity theft, or impersonation
• Submitting false, forged, or misleading documentation
• Tax evasion, sanctions evasion, or concealment of source of funds
• Using mixers, tumblers, or anonymizers to obscure transactions
• Funding or facilitating terrorism, criminal enterprises, or politically exposed person (PEP) abuse
• Market manipulation, including pump-and-dump schemes, wash trading, or deceptive practices
• Engaging in ransomware payments, extortion, or darknet marketplace activity
  
  

3. Prohibited Goods, Services, and Sectors

3.1 Duzo may not be used to process or support transactions related to:

• Sanctioned individuals, governments, or organisations
• Unlicensed gambling, betting, or lottery services
• Illegal narcotics, prescription drugs, or controlled substances
• Pornographic or adult entertainment platforms
• Multi-level marketing (MLM), Ponzi, or high-yield investment schemes (HYIPs)
• Sale or distribution of weapons, explosives, or military-grade equipment
• Privacy coins that restrict transaction traceability (e.g. Monero)
• Unlicensed forex brokers, crypto asset trading platforms, or financial service providers
• Shell banks, unlicensed money service businesses (MSBs), or complex offshore vehicles

3.2 Duzo reserves the right to restrict other high-risk sectors based on regulatory changes, FATF guidance, or internal risk assessment.

4. Jurisdictional Restrictions

4.1 Duzo does not support access from or transactions involving high-risk or sanctioned jurisdictions.

4.2 This includes, but is not limited to:

North Korea, Iran, Syria, and other jurisdictions listed on FATF grey or blacklists or subject to United Nations sanctions.

4.3 Attempting to access Duzo from such regions, or using VPNs or intermediaries to disguise location, may result in immediate account termination.

5. Enforcement and Consequences

5.1 Violations of this Policy may result in immediate enforcement action, including:

• Suspension or termination of your Duzo account
• Freezing of funds pending investigation
• Reversal or rejection of transactions
• Reporting to applicable regulators, law enforcement, or financial partners

5.2 All enforcement actions are taken in accordance with our RMCP and FICA obligations.

6. Reporting Violations

6.1 If you become aware of a violation of this Policy, including unauthorised activity on your account or suspicious behaviour by another user, you must report it immediately to: [email protected].

6.2 Early reporting is essential for the safety and integrity of the Duzo platform.

7. Policy Updates

7.1 This Policy may be amended or updated from time to time in response to legal, regulatory, or operational changes.

7.2 Where appropriate, material changes will be communicated to users in advance. Your continued use of the platform after notification constitutes acceptance of the updated version.