Six categories of restricted industries
The Red List exists because external grant compliance mandates require certain industry exclusions for the Platform to maintain Eligible Entity status with Grant Administrators. It is not an exercise of operational control over independent Subscribers. Select a category below to see specific items, PSA cite anchors, and exception language. The Off-Platform Exception (§5) preserves your independent business activity outside the Platform.
Where the Platform brand may and may not appear
The brand and venue restrictions apply to Platform-associated activities (representing the Platform, wearing or displaying Platform branding, or conducting Platform-associated events). Subscribers' independent off-Platform activities are not restricted here so long as no Platform branding or attribution is involved (see Off-Platform Exception).
The general rule
Subscriber shall not conduct, host, sponsor, or organize any event associated with the Platform, or wear or display Provider's branded materials, at any physical location whose primary business falls within the Red List categories.
§4.1 Alcohol-focused venues
Establishments primarily dedicated to alcohol consumption (bars, nightclubs, dives) even if they serve food, unless the venue is a bona fide restaurant where alcohol is ancillary.
§4.2 Adult, gaming, and gambling venues
Adult entertainment venues, casinos, or gaming halls.
§4.3 Controlled-substance retailers
Retailers of controlled substances or drug paraphernalia.
§4.4 Socially polarized & politically sensitive venues
To preserve neutrality and eligibility for diverse funding sources, Subscriber shall not represent the Platform, deliver speeches, or host networking events at venues primarily associated with controversial or polarized social, medical, or political services (for example, abortion clinics, political campaign headquarters, protest sites, or facilities linked to "Fringe Medicine"), regardless of the Subscriber's personal affiliation with such causes.
§4.5 Relationship to the Off-Platform Exception
The §4 restrictions apply only to Platform-associated activities. Independent business activities off the Platform, with no Platform branding or attribution, are not restricted by §4. See the Off-Platform Exception tab for the full scope of independent-contractor protection.
Independent-contractor protection
Nothing in the Restricted Industries framework prohibits Subscriber from consulting for Red List clients in Subscriber's private capacity as an independent business owner. This exception preserves Subscriber's status as an independent business entity. Activities conducted entirely outside the Platform, without Platform resources and without Platform attribution, are Subscriber's own and are not restricted by this framework.
What remains prohibited even off-Platform
Subscriber is strictly prohibited from the following, regardless of whether the engagement is framed as independent:
§5.1 Platform tools and Platform processing
Processing Red List clients through the Platform or utilizing Ecosystem tools or software for Red List client service delivery.
§5.2 Grant funds and Sponsored credits
Using Grant funds or "Sponsored" credits to subsidize work for Red List clients.
§5.3 Brand association and Success Stories
Publicly associating Provider's brand or "Success Stories" with Red List clients.
What this exception preserves
Subscriber remains free to operate an independent practice that serves any lawful business, including businesses that would be ineligible for Platform service. The exception does not narrow Subscriber's independent commercial freedom; it draws the boundary at the Platform's resources, brand, and grant infrastructure.
How verification works, and what a violation triggers
The Red List is enforced through a layered mechanism: Subscriber screening at intake, Provider verification on reasonable suspicion, periodic re-verification, and a tiered consequence framework that escalates from offboarding through to permanent Ecosystem ineligibility.
§6.1 Dynamic regulatory updates
Provider may amend the Red List unilaterally upon notice to Subscribers, to ensure continued compliance with federal and state funding eligibility. Subscribers have thirty (30) calendar days from notification to initiate offboarding of any affected Clients from the Platform. Off-Platform engagements with such Clients remain unaffected.
§6.2 Right to verification & audit
If Provider reasonably suspects a Client or Sponsor falls within the Red List (through ambiguous marketing, grey-area services, or other surfacing signals), Provider may request verification documentation, including:
- Federal Tax Returns (to verify NAICS codes);
- Business Licenses; and
- Site Inspection Photos.
Failure to provide verification within three (3) business days shall result in immediate suspension of the Client or Sponsor from the Platform.
§6.3 Grey-area escalation
Where a Subscriber is uncertain whether a prospective or active Client falls within the Red List, Subscriber should escalate to Provider through the designated compliance channel before onboarding or continuing service. Provider evaluates the specific facts, may request verification documentation, and issues a determination.
§6.4 Duty to self-report
Subscriber shall immediately notify Provider in writing (within 24 hours) upon discovering that an active Client or Sponsor falls within the Red List or has violated the Venue Restrictions. Cooperation in mitigation includes immediate offboarding and return of any unspent grant funds. Failure to self-report a known violation constitutes Willful Misconduct and waives liability caps.
§6.5 Consequences of violation
A Restricted Industries violation carries tiered consequences that every Subscriber should understand before intake.
Two parallel eligibility tracks, distinct timelines
The Red List framework operates alongside two additional eligibility mechanisms. They share documentary standards but have distinct timelines and finality rules. Recognize which path you are on before acting; the transition window differs.
§7.1 OFAC and sanctions compliance
Clients represent that neither the Client nor any of Client's principals, owners, or officers is listed on the OFAC Specially Designated Nationals and Blocked Persons List, the U.S. Department of Commerce's Entity List, or any other applicable government sanctions list.
§7.2 Discretionary Reputational Risk ("Utah/Nevada" Rule)
What is acceptable in one jurisdiction may be disqualifying in another. Provider reserves the right to reject or offboard a Client strictly if the Client appears on a government Prohibited List (e.g., OFAC) or violates the written Restricted Industries Policy, thereby creating a Demonstrable Banking or Grant Ineligibility that could jeopardize Provider's standing with Grant Administrators.
Per PSA §4.5.4.2, Provider's determination of Objective Ineligibility shall be final provided it is supported by third-party documentation (OFAC list, Merchant Processor ban, or functionally equivalent documentation). Upon notice, Subscriber must immediately cease processing said Client through the Platform's grant-subsidized workflows.
Path clarification: which track applies?
Route a specific situation
Select the scenario that most closely matches what you are screening. The guide surfaces the relevant section and the routing recommendation. For any case that does not clearly match a scenario, escalate to Provider's compliance channel. The determinative question is always "primary revenue or business model," and ambiguous cases warrant a documented Provider determination rather than an at-intake judgment call.
Two procedural paths in summary
§8.1 Clear-Prohibition Path (Subscriber). Collect self-representation of primary business activity at intake. Compare against §3 categories and check §4 Brand & Venue restrictions for planned Platform-associated activities. If a clear fit with any §3 category exists, decline onboarding onto the Platform; the off-Platform engagement remains Subscriber's independent business per §5. If a clear fit with §4 venue restrictions exists, relocate any Platform-associated activity to a compliant venue.
§8.2 Grey-Area Path (Subscriber). If the Client's primary activity is ambiguous or potentially fits a §3 category but also has legitimate non-restricted operations: document the specific ambiguity, escalate to Provider's designated compliance channel per §6.3, and do not onboard or continue service pending determination. Provider may request verification under §6.2 (tax returns, licenses, site photos); Client has three (3) business days to respond. Provider issues determination; Subscriber and Client proceed accordingly.