Prohibited activity
Effective date: 18 September 2026.
DzalekaPay will not onboard these business activities, regardless of a licence held in another market. This list forms part of the Merchant Terms and the User Agreement.
- Illegal drugs and drug equipment. Narcotics, psychotropic substances, and equipment used to make or take them, unless part of a licensed medical supply chain.
- Weapons, arms, and explosives. Making, selling, brokering, or trading arms, ammunition, explosives, or military equipment. A licence does not change this.
- Child sexual abuse material and exploitation of children. Any content, service, or payment that sexualises, exploits, or helps abuse or traffic children.
- Human trafficking, forced labour, and commercial sexual exploitation. Any business connected to trafficking people or forcing them to work. This includes child labour for hire, domestic work extracted by force, and sexual exploitation inside or outside the camp.
- People smuggling and irregular migrant transport. Collecting payment to move people across borders or through Dzaleka without lawful permission. This includes using a shop, lodge, or transport business as a front for smuggling.
- Escort and sexual services. Escort agencies, sexual services, and booking or payment for those services.
- Terrorism and proliferation financing. Any person or activity that supports a designated terrorist organisation, or that helps finance weapons of mass destruction.
- Sanctioned countries, entities, and people. Any party or activity subject to UN, Malawian, or other sanctions lists that apply to our payment rails, including OFAC, EU, and UK lists where they apply.
- Unlicensed gambling, betting, and lottery. Betting, casino, lottery, gaming, or sports bookmaking that does not hold a valid licence for the market it operates in.
- Pyramid schemes and unregistered investment schemes. Schemes that pay returns mainly from new payers' money, and investment schemes that are not properly registered.
- Unlicensed deposit-taking, lending, remittance, or currency exchange. Taking deposits, lending cash, sending remittances, or converting currency. This includes hawala, informal foreign-exchange dealers, and similar off-book transfer. DzalekaPay is not a bank, remittance provider, or foreign-exchange service.
- Counterfeit goods, piracy, and intellectual-property infringement. Selling fake or pirated products, or content that infringes someone else's intellectual property.
- Stolen goods. Trading in goods known or reasonably suspected to be stolen or otherwise unlawfully obtained.
- Illegal wildlife trade and environmental crime. Trading endangered species or products, illegal logging, illegal charcoal or timber, illegal mining, or unlawful dumping of waste.
- Malware, hacking tools, and unlawful surveillance. Selling hacking services, malware, spyware, or tools built to access systems or data without permission.
- Fraud, deception, and scams. Fake documents, fake credentials, get-rich-quick scams, false payment confirmation, and similar deceptive operations.
- Resettlement, visa, and refugee-status scams. Charging people for resettlement slots, refugee status, gate passes, or influence over UNHCR or government procedures. This includes fake UNHCR papers and middleman fees for a process that is free.
- Sale of fake or unauthorised identity and camp documents. Selling or collecting payment for forged or unauthorised refugee documents, asylum papers, gate passes, or immigration letters.
- Mobile-money, SIM-swap, and impersonation fraud. A business whose purpose is tricking people into sending mobile money, taking over SIM cards or WhatsApp accounts, or impersonating officials, relatives, or DzalekaPay.
- Diverted humanitarian aid. Collecting payment for ration cards, food, cash assistance, or other relief supplies that were issued for personal use and then sold as a commercial stock.
- Payments that fund political or ethnic violence. Collections that pay for armed groups, revenge attacks, or political or ethnic violence in the camp or in a country of origin.
- Trade in human body parts, organs, or remains. Any commercial dealing in human organs, tissue, or remains, outside lawful medical or scientific use.
- Adult content and adult entertainment. Pornography, adult entertainment platforms, and any sexual content or services. Age checks or classification do not change this.
- Hate speech and incitement to violence. Platforms or merchants whose main purpose is promoting hatred, discrimination, or violence against a protected group.
- Unlicensed sale of medicines. Selling or dispensing prescription or non-prescription medicines without a lawful supply chain.
- Alcohol and tobacco. Alcohol or tobacco sales, unless camp authorities licensed the activity and a DzalekaPay compliance officer confirmed that licence.
- Shell companies. Companies with no real business activity, no economic substance, or unclear ownership, used mainly to hold or move money.
- Unverified charitable collection. Fundraising that is not a reviewed DzalekaPay campaign, or that we reasonably believe is not a genuine community organisation.
- Unsolicited payment collection. Collecting payments from people who did not agree to pay you, including deceptive or cold-call collection.
- Regulated activity without the required licence or controls. Operating in a regulated sector without the required licence, or without adequate compliance controls.
- Any other material risk. Any other activity that, in our reasonable assessment, poses material legal, financial-crime, or reputational risk to DzalekaPay, PayChangu, or payers. We assess this case by case, even if it is not listed above.
This list is not exhaustive. If you are unsure, email info@mail.dzaleka.com before you collect payments. Full HTML page: https://pay.dzaleka.com/prohibited-activity.