AML & KYC Policy
Last updated: April 10, 2026
1. Introduction
1.1 This AML & KYC Policy describes the procedures applied by the Company to prevent money laundering, terrorist financing, fraud, and other illegal activities.
1.2 The Company is committed to maintaining a risk-based compliance framework aligned with generally accepted international standards and recommendations, including FATF guidelines.
1.3 By using the Platform, the Client agrees to comply with this Policy.
2. Definition of Money Laundering
2.1 Money laundering refers to activities intended to conceal or disguise the origin of illegally obtained funds.
2.2 It typically occurs in three stages:
- Placement — introduction of funds into the financial system;
- Layering — movement of funds to obscure their origin;
- Integration — reintroduction of funds into the economy as legitimate assets.
2.3 The Company applies appropriate measures to detect and prevent such activities.
3. Risk-Based Approach
3.1 The Company applies a risk-based approach to AML & KYC compliance.
3.2 Each Client is assessed based on factors including, but not limited to:
- geographic location;
- transaction behavior;
- payment methods;
- account activity patterns;
- risk indicators identified by internal systems.
3.3 The level of verification and monitoring applied to each Client may vary depending on the assessed risk.
4. Client Identification (KYC)
4.1 The Client may be required to provide identification documents, including:
- passport or national ID;
- proof of address (utility bill, bank statement);
- additional documents where necessary.
4.2 The Company may request additional verification measures, including:
- selfie verification;
- video identification;
- biometric checks where applicable.
4.3 The Company reserves the right to request verification:
- at the time of registration;
- before processing withdrawals;
- at any time during account activity.
4.4 Failure to complete verification may result in:
- restriction of account functionality;
- suspension of transactions;
- account termination.
5. Source of Funds
5.1 The Company may request information or documentation confirming the origin of funds.
5.2 Such documentation may include:
- bank statements;
- payment confirmations;
- proof of income;
- business activity documentation;
- any other supporting materials deemed necessary.
5.3 Failure to provide sufficient information may result in restrictions, delays, or refusal of transactions.
6. Ongoing Monitoring
6.1 The Company performs ongoing monitoring of Client activity.
6.2 Monitoring may include:
- transaction analysis;
- behavioral pattern recognition;
- detection of unusual or high-risk activity;
- automated and manual review processes.
6.3 The Company reserves the right to reassess Client risk levels at any time.
7. Sanctions and Screening
7.1 The Company applies sanctions screening and compliance procedures in accordance with internationally recognized standards and applicable sanctions regimes, including but not limited to sanctions, restrictive measures, and watchlists issued by the United Nations (UN), the European Union (EU), the Office of Foreign Assets Control (OFAC), and other competent authorities.
7.2 The Company screens Clients, beneficial owners, representatives, counterparties, transactions, payment methods, source of funds, and other relevant information against applicable sanctions lists, politically exposed persons (PEP) databases, adverse media sources, and other risk-based compliance databases.
7.3 In accordance with its internal policies, the Company does not open Accounts, provide services, or process transactions for individuals who:
- are subject to economic, financial, trade, or other sanctions or restrictive measures;
- are citizens or residents of countries or territories where transactions are prohibited or restricted by applicable international sanctions;
- are located in, operating from, or otherwise connected to restricted or sanctioned countries or territories;
- are identified as high-risk based on criteria determined by the Company’s Compliance Department;
- are involved in, suspected of involvement in, or connected to money laundering, terrorist financing, fraud, sanctions evasion, or other illegal conduct.
7.4 Restricted and Sanctioned Countries
The list of restricted countries and territories is determined and regularly reviewed based on applicable sanctions regimes, FATF high-risk jurisdictions and jurisdictions under increased monitoring, AML/CTF risk indicators, geopolitical risk, corruption risk, terrorist financing risk, regulatory requirements, payment provider requirements, and the Company’s internal risk assessment and risk appetite.
Currently, the Company treats the following countries and territories as restricted:
- Afghanistan;
- Belarus;
- Central African Republic;
- Congo;
- Cuba;
- Democratic Republic of Congo;
- Iran;
- Iraq;
- Lebanon;
- Libya;
- Mali;
- Myanmar;
- North Korea;
- Russian Federation;
- Somalia;
- South Sudan;
- Sudan;
- Syria;
- Venezuela;
- Yemen;
- Zimbabwe;
- Crimea (Ukraine);
- Donetsk region (Ukraine);
- Luhansk region (Ukraine);
- non-government controlled / occupied areas of Zaporizhzhia region (Ukraine);
- non-government controlled / occupied areas of Kherson region (Ukraine).
7.5 The Company may, at its sole discretion, restrict or deny access to the Platform, refuse onboarding, suspend or terminate Accounts, freeze or reject transactions, request additional information, or apply enhanced due diligence where required by:
- regulatory requirements;
- sanctions screening results;
- risk assessment results;
- payment provider restrictions;
- internal compliance policies;
- the Company’s internal risk appetite.
7.6 The Company reserves the right to update, amend, expand, or modify the list of restricted countries, territories, persons, entities, activities, and transactions at any time without prior notice, based on changes in applicable laws, sanctions regimes, regulatory expectations, payment provider requirements, or the Company’s internal risk assessment.
8. Risk Scoring
8.1 Accounts may be assigned internal risk scores based on Client profile and activity.
8.2 Risk scoring may influence:
- verification requirements;
- transaction limits;
- withdrawal processing conditions;
- account status and restrictions.
9. Restrictions and Measures
9.1 In order to ensure compliance, the Company may:
- request additional information or documentation;
- temporarily restrict Account functionality;
- delay or refuse transactions;
- suspend or terminate the Account.
9.2 Such measures may be applied where there is a reasonable concern regarding compliance, security, or risk.
10. Client Responsibilities
10.1 The Client must provide accurate, complete, and up-to-date information.
10.2 The Client must not:
- use false or misleading information;
- use third-party identities;
- use unauthorized payment methods;
- attempt to bypass verification procedures.
10.3 The Client is responsible for notifying the Company of any changes to personal data.
11. Reporting
11.1 The Company may report suspicious activities to relevant authorities where required by applicable laws and regulations.
11.2 The Company may cooperate with regulatory, law enforcement, and financial institutions in accordance with legal obligations.
12. Data Retention
12.1 The Company may retain Client data for a period necessary to:
- comply with legal and regulatory obligations;
- prevent fraud and abuse;
- resolve disputes;
- enforce agreements.
13. Third-Party Verification
13.1 The Company may use third-party service providers for identity verification, fraud detection, and compliance checks.
13.2 Such providers may process data in accordance with their own policies and applicable regulations.
14. Contact
14.1 For AML & KYC related inquiries, Clients may contact: