Account Suspension & Termination Policy
This policy explains when and how NeFin Solutions, UAB may suspend or terminate an account, how we notify clients, and what happens to funds and data. It complements the Terms and Conditions.
1. Purpose & scope
When this policy applies and the documents it works with.
This policy sets out the principles and procedures for account suspension and termination by NeFin Solutions, UAB (“the Company”). It should be read together with the Terms and Conditions, Prohibited Jurisdictions List, Restricted Activities Policy, Privacy Policy (GDPR), Travel Rule Statement and Complaints Policy.
2. Grounds for suspension or termination
Main reasons we may restrict or end services.
- AML/CTF & sanctions: suspicion of money laundering/terrorist financing; match with sanctions lists; links to prohibited jurisdictions or sanctioned persons/entities.
- KYC/KYB failures: refusal to provide, or provision of false/forged documents; inability to verify identity, address, SoF/SoW; failure to complete EDD.
- Restricted activities: involvement in activities listed in the Restricted Activities Policy (e.g., unlicensed financial services, mixing/tumbling, darknet markets).
- Fraud & security: account compromise, credential sharing, chargeback abuse, phishing or malware activity.
- Regulatory/legal request: order or request from competent authorities (e.g., FIU, law enforcement, courts, regulators).
- Terms breach: material breach of the Terms and Conditions or other agreements (MSA/order forms).
- Non-payment / negative balance: failure to settle fees or obligations; persistent negative balances.
- Inactivity: prolonged inactivity beyond thresholds defined by the Company, where security or compliance risks arise.
- Misuse: platform abuse, market manipulation, misuse of promotions, or attempts to circumvent controls (including geoblocking and Travel Rule checks).
3. Process & timelines
How we act, notify you, and what you can expect.
- Immediate measures: in high-risk cases, the Company may impose an immediate temporary suspension (e.g., login lock, trading/withdrawal hold) without prior notice to protect clients, assets and comply with law.
- Notification: unless prohibited by law, we inform the client of suspension and reasons as soon as reasonably practicable via registered email in the account profile.
- Information request: we may request additional documents/information (e.g., updated KYC, SoF/SoW). The client must respond within the deadline specified (typically 3–5 business days).
- Assessment & decision: following assessment, the Company either lifts the suspension, keeps it until issues are resolved, or proceeds to termination.
- Termination notice: where feasible, we provide written notice with effective date and next steps for asset withdrawal or retention.
4. Treatment of funds, assets & open orders
What happens to balances, withdrawals, and orders.
- Open orders: may be cancelled upon suspension or termination.
- Withdrawals: permitted where legally and operationally possible, subject to completion of KYC/EDD and sanctions screening.
- Retention / freeze: the Company may retain or freeze assets where required by law, regulator request, court order, or internal AML/CTF controls.
- Set-off: the Company may set off unpaid fees or negative balances against client assets in accordance with the Terms and Conditions.
- Network & partner constraints: blockchain network conditions, Travel Rule requirements, or partner bank/PSP rules may affect timing of withdrawals.
5. Restoration & reactivation
How an account may be re-enabled.
Suspended accounts may be restored once outstanding issues are resolved (e.g., successful KYC/EDD, satisfactory SoF/SoW, risk cleared). The Company may require additional controls (e.g., MFA reset, address whitelisting) before reactivation.
6. Client-initiated closure
How you can close your account.
Clients may request account closure at any time by contacting support@nefin.io. The Company may need to complete final KYC/EDD checks and settle outstanding obligations before closure.
7. Records, reporting & data protection
How we keep records and protect your data.
- Recordkeeping: suspension/termination decisions and related evidence are recorded in internal systems for at least the statutory period.
- Regulatory reporting: suspicious activity may be reported to FIU or other authorities as required by law.
- Data protection: personal data is processed under GDPR; see our Privacy Policy.
8. Appeals & complaints
If you disagree, how to appeal or complain.
Clients may submit additional information for reconsideration or file a complaint under the Complaints Policy. This does not affect the Company’s obligations to comply with AML/CTF and legal requirements.
9. General provisions
Changes to this policy and governing law.
- This policy may be updated from time to time. The latest version is available on this page.
- This policy is governed by the laws of Lithuania and should be read with the Terms and Conditions.
10. Contact
Questions about this policy? Contact us.
NeFin Solutions, UAB
Savanorių pr. 187-301, LT-02300 Vilnius, Lithuania
Email: support@nefin.io