This Terms of Service (“Agreement”) is a contract between you and Bpay and applies to your
use of Bpay Services. You must read, agree with and accept all of the terms and conditions
contained in this Agreement. This is an important document which you must consider carefully
when choosing whether to use Bpay Services. When using the Bpay’s payment Services, you
shall be bound by this Terms of Service.
In some cases, a merchant may be required to execute a special payment service agreement.
In case of conflict between this Terms of Service and a special payment agreement, the
latter shall prevails
A company duly registered with the Bangko Sentral ng Pilipinas (BSP) as an Operator of
Payment Systems (OPS). It offers payment Services under the BPAY brand.
refers to the Payments platform owned and operated by Bexpress Inc., and its ancillary
Services, including, but not limited to, the payments platform, the application programming
interface (hereinafter, the “API”), and the point-of-sale terminal system (hereinafter, the
A natural or legal person, the identifying information of whom and/or by whom was provided
to Bpay to enable access to Bpay’s Services. This also includes any persons using a Bpay
account on behalf of a Bpay Customer, any unauthorized users of a Bpay Account, and any
person(s) otherwise controlling a Bpay account.
Refers to an account that is linked to any Bpay Customer identifying information.
1.2. CONTACT DETAILS.
Bpay Customer Service Hotline No. (02) 8815-7712.
BSP – Financial Consumer Protection Department (Tel. No.: (632) 708.7325; Fax No.: (632)
1.3. By signing up to use the Bpay account through the Site “http://bpay.ph/” website
and/or Bpay mobile application, the Bpay API, and/or any associated websites or mobile
applications (collectively the “Bpay site”), you agree to comply with and be legally bound
by this Agreement, as revised from time to time. If you do not agree to any of the terms
set forth in 1 this Agreement, or any subsequent modification to the Agreement, you may not
access or use any of the Bpay Services.
1.4. We may amend or modify this Agreement by posting on the Bpay site or emailing you the
revised Agreement, and the revised Agreement shall be effective at such time. We may (a)
modify or discontinue any portion of the Bpay Services, and (b) suspend or terminate your
access to the Bpay Services, at any time, and from time to time, without notice to you in
certain, limited circumstances described herein. You agree that we shall not be liable to
you or any third party for any modification or termination of the Bpay Services, or
suspension or termination of your access to the Bpay Services, except to the extent
otherwise expressly set forth herein.
Bexpress Inc., with its registered address at 1/F Unit 5, Aseana Powerstation Bldg. Pres.
Macapagal blvd. Cor. Bradco Ave. Brgy. Baclaran, Parañaque City, Philippines, including,
without limitation, its owners, directors, investors, employees or other related parties.
Depending upon the context, “Bpay” may also refer to the Services, products, website,
content or other materials (collectively “Bpay Services” or “Services”) provided by Bpay.
1.6. Bpay is duly registered with the Bangko Sentral ng Pilipinas (BSP) as an Operator of
Payment Systems, and such activity is subject to the rules and regulations of the Bangko
Sentral ng Pilipinas and the Anti-Money Laundering Council (AMLC). As a regulated business,
BPay is required to comply with the Anti-Money Laundering Act, which requires BPay to
verify merchant identities, maintain records of currency transactions for up to five and
report certain covered and suspicious transactions. In the event that a merchant account is
closed by BPay or at the request of the merchant, even without completing the onboarding
process or performing a transaction, records must be held as prescribed by law.
1.7. Access to the Service. Depending on your country of residence, you may not be able to
use all the functions of the Site. It is your responsibility to follow those rules and laws
in your country of residence and/or country from which you access this Site and Services.
As long as you agree to and comply with these Terms of Service, Bpay grants you the
personal, non-exclusive, non-transferable, non-sublicensable and limited right to enter
and use the Site and the Service.
1.8. To use Bpay’s Services, you must open a BPay account. When you open an account, we
will ask you for contact information such as your name, phone number, email address, and
information relating to the ultimate beneficial owner or the most senior individual from
the organization. We will also ask you for information on your business, including your
business’s legal name or DBA, physical address of the business, and your company's website.
The information that you provide at the time of account opening must be accurate and
complete and you must inform us within ten business (10) days of any changes to such
information. We may require additional information from you (including any person signing
below or otherwise agreeing to the Terms on behalf of the merchant) to help verify your
identity and assess your business risk, such as your date of birth, tax identification
number, or government-issued identification. We may also obtain information about you from
third parties, such as credit bureaus and identity verification services. We have the right
to reject your account registration or to later close your BPay account, if you do not
provide us with accurate, complete, and satisfactory information
1.9. Risk Disclosure. Please note the following risks associated with the use of Bpay
● Bpay uses blockchain technology to process payment transaction. It is possible for a
blockchain transaction to remain unconfirmed for a period of time. In such case, the
cryptocurrency or blockchain transaction shall be deemed to be made when recorded on a
public ledger, which is not necessarily the date or time that the customer initiates
● Cryptocurrencies are not legal tender, is not backed by the government, and accounts and
value balances are not subject to deposit insurance;
● Legislative and regulatory changes or actions at the state, federal, or international
level may adversely affect the use, transfer, exchange, and value of cryptocurrency;
● transactions in cryptocurrency may be irreversible, and, accordingly, losses due to
fraudulent or accidental transactions may not be recoverable;
● there is no assurance that a person who accepts cryptocurrency as payment today will
continue to do so in the future;
● the volatility and unpredictability of the price of cryptocurrency relative to fiat
currency may result in significant loss over a short period of time;
● The software protocols that underlie cryptocurrencies and blockchains are typically open
source projects, which means that (i) the development and control of blockchains is outside
of BEXPRESS’ control and (ii) such software protocols are subject to sudden and dramatic
changes that might have a significant impact on the availability, usability or value of a
● BEXPRESS may experience sophisticated cyber-attacks, unexpected
surges in activity or other operational or technical difficulties that may cause
interruptions to the Services. YOU UNDERSTAND THAT THE SERVICES MAY EXPERIENCE OPERATIONAL
ISSUES THAT COULD LEAD TO DELAYS. YOU AGREE TO ACCEPT THE RISK OF TRANSACTION FAILURE
RESULTING FROM UNANTICIPATED OR HEIGHTENED TECHNICAL DIFFICULTIES, INCLUDING THOSE
RESULTING FROM SOPHISTICATED ATTACKS.
2. OUR RELATIONSHIP WITH YOU.
2.1 Bpay helps you process payments using blockchain technology. Bpay is an independent
contractor for all intents and purposes. Bpay does not have control of, or liability for,
the products or Services that are paid for with Bpay Services.
Protecting your privacy is very important to Bpay. Please review our
your privacy, as well as our use and disclosure of your information.
2.3 Privacy of Others; Marketing.
If you inadvertently receive information about another user through the Bpay Services, you
must keep the information confidential and only use it in connection with Bpay Services.
You may not disclose or distribute a user’s information to a third party or use the
information for marketing purposes unless you receive the user’s express consent to do so.
You may not send unsolicited email to a user through the Bpay.
2.4 Intellectual Property.
“Bpay” and all logos related to the Bpay Services and/or Bpay Services are either
trademarks, or registered marks of Bpay, their registered owners or its licensors. The
Trademarks and Material should not be copied, reproduced, modified, republished, uploaded,
posted, transmitted, scraped, collected or distributed in any form or by any means, whether
manual or automated. The use of any such Materials on any other Site or networked computer
environment for any other purpose is strictly prohibited; any such unauthorized use may
violate copyright, trademark and other applicable laws and could result in criminal or
2.5 Password Security and Keeping Your Email and Address Current.
You are responsible for maintaining adequate security and control of any and all IDs,
passwords, personal identification numbers (PINs), or any other codes that you use to
access Bpay Services. You are responsible for keeping your email address up to date in your
Account Profile. You are responsible for maintaining the confidentiality and security of
any and all account names, User IDs, passwords and any other security feature that you use
to access the Services. You are responsible for (i) keeping your email address up to date
in your Account profile and (ii) maintaining the confidentiality of your User information
and the security of your Account, which includes the enabling of all relevant security
features. You agree to notify Bpay immediately if you become aware of any unauthorized use
of the Services or any other breach of security regarding the Services. BEXPRESS will not
be liable for any loss or damage arising from your failure to protect your Account or your
2.6 Notices to You.
You agree that Bpay, via Bpay platform, App and/or Web Portal may provide you communications
about your Account and Bpay Services electronically.
2.7 Notices to Bpay.
We prefer receiving notices electronically through our support system at
Paper notifications can also be sent. See our contact page for our mailing address.
2.8. Third Party Applications.
If you grant express permission to a third party to connect to your Bpay account, either
through the third party’s product or through Bpay, you acknowledge that granting permission
to a third party to take specific actions on your behalf does not relieve you of any of your
responsibilities under this Agreement. Further, you acknowledge and agree that you will not
hold Bpay responsible for, and will indemnify Bpay from, any liability arising from the
actions or inactions of this third party in connection with the permissions you grant. You
may change or remove these permissions at any time from the Account Settings (API) page.
It is your responsibility to determine what, if any, taxes apply, it is your responsibility
to collect, report and remit the correct tax to the appropriate tax authority. Bpay is not
responsible for determining whether taxes apply to your transaction, or for collecting,
reporting or remitting any taxes arising from any transaction.
Bpay may delay an order if customer has not provided personal identifying information, if
it reasonably suspects that customer is in violation of the User Agreement, or if further
personal identifying information is necessary to establish the identity of the customer
(“KYC”). Until completion of such verification procedures, customers may experience delayed
processing of digital currency Transactions or Conversion Service transactions. Bpay will
designate any such delayed transaction as “pending,” and funds will not be available until
the pending transaction is completed. Bpay reserves the right to refuse to process, cancel,
or to reverse any customer transaction (i) as required by law, (ii) in response to a
facially valid subpoena, court order, or other government order, or (iii) if reasonably
suspects that the transaction is erroneous, or is in violation of the Bpay User Agreement.
You are also responsible for maintaining the confidentiality of your Account information,
including your password, safeguarding your own Cryptocurrencies, and all activity including
Transactions that are posted to your Account. IF THERE IS SUSPICIOUS ACTIVITY RELATED
TO YOUR ACCOUNT, WE MAY, BUT ARE NOT OBLIGATED TO, REQUEST ADDITIONAL INFORMATION FROM YOU,
INCLUDING AUTHENTICATING DOCUMENTS, AND TO FREEZE ANY TRANSACTIONS PENDING OUR REVIEW. YOU
ARE OBLIGATED TO COMPLY WITH THESE SECURITY REQUESTS OR ACCEPT TERMINATION OF YOUR ACCOUNT.
YOU ARE REQUIRED TO NOTIFY BPAY IMMEDIATELY OF ANY UNAUTHORISED USE OF YOUR ACCOUNT OR
PASSWORD, OR ANY OTHER BREACH OF SECURITY, BY EMAIL TO SUPPORT@BEXPRESS.PH. ANY USER WHO
VIOLATES THESE RULES MAY BE TERMINATED, AND THEREAFTER HELD LIABLE FOR LOSSES INCURRED BY
BPAY OR ANY USER OF THE SITE.
3.3. BPAY RESERVES THE RIGHT TO REFUSE TO PROCESS, OR TO CANCEL OR REVERSE, ANY
TRANSACTIONS, EVEN AFTER FUNDS HAVE BEEN DEBITED FROM YOUR ACCOUNT(S), IF BPAY SUSPECTS THE
TRANSACTION INVOLVES (OR HAS A HIGH RISK OF INVOLVEMENT IN) MONEY LAUNDERING, TERRORIST
FINANCING, FRAUD, OR ANY OTHER TYPE OF FINANCIAL CRIME; IN RESPONSE TO A SUBPOENA, COURT
ORDER, OR OTHER GOVERNMENT ORDER; IF BPAY REASONABLY SUSPECTS THAT THE TRANSACTION IS
ERRONEOUS; OR IF BPAY SUSPECTS THE TRANSACTION BPAY WILL REVERSE THE TRANSACTION. IN THE
CASES OF DIGITAL CURRENCY TRANSACTION, WE ARE UNDER NO OBLIGATION TO ALLOW YOU TO REINSTATE
A PURCHASE OR SALE ORDER AT THE SAME PRICE OR ON THE SAME TERMS AS THE CANCELLED TRANSACTION.
3.4 Bpay will make reasonable efforts to ensure that payments are processed in a timely
manner within our advertised processing times. But Bpay makes no representations or
warranties regarding the amount of time needed to complete processing which is dependent
upon many factors outside of our control.
3.5. Suspension and Cancellation.
We may suspend your access to Bpay Services in accordance with the suspension and
termination terms of this Agreement. Suspension or termination shall not affect the payment
of fees or other amounts you owe to Bpay. In the event that your Bpay is suspended or
terminated, we will immediately cancel all open orders associated with your Bpay Account,
block all withdrawals and bar the placing of further orders until resolution or Account
3.6 No Warranty.
We do not represent that Bpay and/or the Bpay Services will be available without
interruption. Although we will strive to provide you with continuous operations, we do not
guarantee continuous access or that there will be no delays, failures, errors, omissions or
loss of transmitted information, nor do we guarantee that any order will be executed,
accepted, recorded, or remain open. Bpay reserves the right to cancel any open trades and/or
suspend Bpay activity in accordance with the below Trading Rules. YOU FURTHER ACKNOWLEDGE
THAT INFORMATION YOU STORE OR TRANSFER THROUGH OUR SERVICES MAY BECOME IRRETRIEVABLY LOST
OR CORRUPTED OR TEMPORARILY UNAVAILABLE DUE TO A VARIETY OF CAUSES, INCLUDING SOFTWARE
FAILURES, PROTOCOL CHANGES BY THIRD PARTY PROVIDERS, INTERNET OUTAGES, FORCE MAJEURE EVENT
OR OTHER DISASTERS INCLUDING THIRD PARTY DDOS ATTACKS, SECURITY BREACH, SCHEDULED OR
UNSCHEDULED MAINTENANCE, OR OTHER CAUSES EITHER WITHIN OR OUTSIDE OUR CONTROL. YOU ARE
SOLELY RESPONSIBLE FOR BACKING UP AND MAINTAINING DUPLICATE COPIES OF ANY INFORMATION YOU
STORE OR TRANSFER THROUGH OUR SERVICES.
4. DISPUTES WITH BPAY.
You agree to indemnify and hold Bpay, its parent, the officers, directors, agents, joint
venturers, and employees harmless from any claim or demand (including attorneys’ fees)
arising out of your breach of this Agreement or your use of Bpay Services.
In the event of an error, whether computer or human error, or whether via our Services,
in a purchase order confirmation, in processing your purchase or payment, or otherwise, we
reserve the right to correct such error and revise your payment transaction accordingly
(including charging the correct price) or to cancel the purchase and refund any amount received.
4.3. Release of Bpay.
If you have a dispute with one or more users, you release Bpay (and our parent, officers,
directors, agents, joint ventures, employees and suppliers) from any and all claims,
demands and damages (actual and consequential) of every kind and nature arising out of or
in any way connected with such disputes. In addition, this release extends to claims which
the creditor does not know or suspect to exist in his favor at the time of executing the
release, which if not known by him must have materially affected his settlement with the
4.4. Disputes with Bpay.
If you think we have made an error, email us at email@example.com. In your correspondence,
you must give us information sufficient to identify you, your account, and the transaction
on which you believe an error occurred. You must contact us within thirty (30) days after
the transaction occurred. Within thirty (30) days of receiving your request, we must either
correct the error or explain to you why we believe the transaction was correct.
4.5. Service Level Commitment on Complaints and Disputes.
Within fifteen (15) business days of our receipt of your complaint, a Customer Assistance
Officer will address all points raised in your complaint by sending you an email
("Resolution Notice") in which the Officer will: (i) offer to resolve your complaint in the
way your requested; (ii) make a determination rejecting your complaint and set out the
reasons for the rejection; or (iii) offer to resolve your complaint with an alternative
solution. In exceptional circumstances, if the Officer is unable to respond to your
complaint within 15 business days for reasons beyond BEXPRESS' control, the Officer will
send you a holding reply indicating the reasons for a delay in answering your complaint and
specifying the deadline by which the Officer will respond to your complaint (which will be
no later than 30 days from our receipt of your complaint. Any offer of resolution made to
you will only become binding on us if accepted by you. An offer of resolution will not
constitute any admission by us of any wrongdoing or liability regarding the subject matter
of the complaint.
5. GENERAL PROVISIONS.
5.1 Limitations of Liability.
IN NO EVENT SHALL WE, OUR PARENT, THE OFFICERS, DIRECTORS, AGENTS, JOINT VENTURERS,
EMPLOYEES AND SUPPLIERS OF BPAY OR OUR PARENT BE LIABLE FOR LOST PROFITS OR ANY SPECIAL,
INCIDENTAL OR CONSEQUENTIAL DAMAGES ARISING OUT OF OR IN CONNECTION WITH OUR WEBSITE, BPAY
SERVICES, OR THIS AGREEMENT (HOWEVER ARISING, INCLUDING NEGLIGENCE). Some states do not
allow the exclusion or limitation of incidental or consequential damages so the above
limitation or exclusion may not apply to you. OUR LIABILITY, AND THE LIABILITY OF OUR
PARENT, OFFICERS, DIRECTORS, AGENTS, JOINT VENTURERS, EMPLOYEES AND SUPPLIERS, TO YOU OR
ANY THIRD PARTIES IN ANY CIRCUMSTANCE IS LIMITED TO THE ACTUAL AMOUNT OF DIRECT DAMAGES
5.2 No Warranty.
BPAY SERVICES ARE PROVIDED “AS IS” AND WITHOUT ANY REPRESENTATION OF WARRANTY, WHETHER
EXPRESS, IMPLIED OR STATUTORY. BPAY, OUR PARENT, THE OFFICERS, DIRECTORS, AGENTS, JOINT
VENTURERS, EMPLOYEES AND SUPPLIERS OF Bpay OR OUR PARENT SPECIFICALLY DISCLAIM ANY IMPLIED
WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT.
Bpay does not have any control over the products or Services that are paid for with Bpay
Services and Bpay cannot ensure that a buyer or a seller you are dealing with will actually
complete the transaction or is authorized to do so. Bpay does not guarantee continuous,
uninterrupted or secure access to any part of Bpay Services, and operation of our site may
be interfered with by numerous factors outside of our control. Bpay will make reasonable
efforts to ensure that requests for electronic debits and credits involving bank accounts
and check issuances are processed in a timely manner but Bpay makes no representations
or warranties regarding the amount of time needed to complete processing because Bpay
Services are dependent upon many factors outside of our control, such as delays in the
5.3 Force Majeure.
We shall not be liable for delays, failure in performance or interruption of Service which
result directly or indirectly from any cause or condition beyond our reasonable control,
including but not limited to, any delay or failure due to any act of God, act of civil or
military authorities, acts of terrorists, civil disturbance, war, strike or other labor
dispute, fire, interruption in telecommunications or Internet Services or network provider
Services, failure of equipment and/or software, blockchain network congestion, contentious
hard forks, catastrophic blockchain or smart contract code error and other catastrophes or
any other occurrences which are beyond our reasonable control.
5.4 Dispute Resolution; Arbitration.
All disputes, issues, controversies or differences arising out of or in connection with
this Agreement shall first be resolved amicably within thirty (30) calendar days after
written notice thereof has been given by the complaining party to the counterparty.
Disputes, controversies or claims arising out of or in connection with this Agreement that
are not resolved within 30 calendar days shall be referred to and settled by a tribunal
comprised of one (1) arbitrator to be appointed by the Philippine Dispute Resolution Center,
Inc. (PDRCI); The seat of arbitration will be Makati City, Philippines, the location
determined by the PDRCI, the language of arbitration will be English and the rules
established by the PDRCI shall govern the process. The arbitration tribunal will have the
right to issue injunctions and its decision will be compulsory, final and strictly
mandatory to the parties who in turn waive any other jurisdiction or venue that may apply
and agree to be subject to the arbitral decision waiving any appeals of any type.
5.5 Time Limitation on Claims.
You agree that any claim you may have arising out of or related to your relationship with
Bpay must be filed within one (1) year after the date of the relevant transaction,
whichever is earlier; otherwise, your claim is permanently barred.
5.6. Export Controls & Sanctions.
Bpay Services are subject to the Philippines and international export controls and economic
sanctions requirements. By availing of Bpay’s Services, you represent and warrant that you
are not a resident of any of the restricted jurisdictions below. Without limiting the
foregoing, you may not avail of any of the Bpay Services if: (1) you are in, under the
control of, or a national or resident of Cuba, Iran, North Korea, Sudan or Syria or any
other country subject to United States embargo, UN sanctions, HM Treasury’s financial
sanctions regime, or if you, or your cryptocurrency wallet address, or the cryptocurrency
wallet address of your intended recipient or the source of your cryptocurrency, are on the
U.S. Treasury Department’s Specially Designated Nationals List or the U.S. Commerce
Department’s Denied Persons List, Unverified List, Entity List HM Treasury’s financial
sanctions regime; or (2) you intend to supply the acquired digital currency or Bpay
Services to Cuba, Iran, North Korea, Sudan or Syria or any other country subject to United
States embargo or UN sanctions (or a national or resident of one of these countries), or to
a person on the Specially Designated Nationals List, Denied Persons List, Unverified List,
Entity List, or HM Treasury’s financial sanctions regime.
5.7. Choice of Law.
This Agreement, and its application and interpretation, shall be governed exclusively by
the laws of the Philippines, without regard to its conflict of law rules.
6. PROHIBITED BUSINESSES AND PROHIBITED USE
6.1. The following categories of businesses, business practices, and sale items are barred
from Bpay Services (“Prohibited Businesses”). By opening a Bpay account, you confirm that
you will not use Bpay Services in connection with the following businesses, activities,
practices, or items:
1. Operating as an unlicensed payment, money transmitter, money Service, payment Service
provider, e-money, or any other financial Services business which requires licensure,
including but not limited to exchanges of virtual currencies, sales of money orders or
traveler’s checks, and escrow Services
2. Counterfeit products or any product or Service that infringes upon the copyright,
trademark, or trade secrets of any third party
3. Stolen goods
4. Narcotics, controlled substances, prescription and pharmaceutical Services, drug
paraphernalia, or any substances designed to mimic illegal drugs
5. Prostitution or illegal escort Services
6. Violent acts towards self or others, or activities or items that encourage, promote,
facilitate or instruct others regarding the same
7. Funding any of the items included on this Prohibited Businesses list
8. Extortion, blackmail, or efforts to induce unearned payments
9. Unlicensed sale of firearms and certain weapons
10. Engaging in deceptive marketing practices
11. Any business that violates any law, statute, ordinance or regulation
6.2. You may not use Bpay Services to engage in the following categories of activity
(“Prohibited Use”). By opening a Bpay Account operated by Bpay, you confirm that you will
not use your Account to do any of the following:
1. Violate or assist any party in violating any law, statute, ordinance, regulation or any
rule of any self-regulatory or similar organization of which you are or are required to be
a member (for example, those laws, rules, or regulations governing financial Services,
controlled substances, or consumer protections);
2. Partake in a transaction which involves the proceeds of any unlawful activity;
3. Defraud or attempt to defraud Bpay or other Bpay users;
4. Infringe upon Bpay’s or any third party’s copyright, patent, trademark, or intellectual
5. Provide false, inaccurate or misleading information;
6. Take any action that imposes an unreasonable or disproportionately large load on our
infrastructure, or detrimentally interfere with, intercept, or expropriate any system,
data, or information;
7. Interfere with another individual’s or entity’s access to or use of any of the Bpay
8. Defame, abuse, harass, stalk, threaten or otherwise violate or infringe the legal rights
(such as, but not limited to, rights of privacy, publicity and intellectual property) of
9. Publish, distribute or disseminate any unlawful material or information;
10. Transmit or upload any material to the Bpay Site that contains viruses, Trojan horses,
worms, or any other harmful or deleterious programs;
11. Harvest or otherwise collect information from the Bpay Site about others, including
without limitation email addresses, without proper consent;
12. Act as a payment intermediary or aggregator or otherwise resell any of the Bpay
Services, unless expressly authorized by Bpay in writing;
13. Transfer any rights granted to you under this Agreement;
14. Use the Bpay Account information of another party to access or use the Bpay ecifically
authorized by a user to access such user’s Bpay Account and information;
15. Otherwise attempt to gain unauthorized access to the Bpay Site, other Bpay Accounts,
computer systems or networks connected to the Bpay Site, through password mining or any
16. Engage in transactions involving items that infringe or violate any copyright,
trademark, right of publicity or privacy or any other proprietary right under the law;
17. Take any action that Bpay deems as circumventing Bpay controls, including, but not
limited to, opening multiple Bpay Accounts or abusing promotions which Bpay may offer from
time to time;
18. US Residents are prohibited from using Bpay for money transmission or to conduct any
other financial activity requiring licensure or covered by regulations governing financial