AML Policy

This policy summarises the anti-money-laundering and sanctions controls applied to every payment flowing through the gateway.

Sanctions screening

Inbound and outbound addresses are screened against the OFAC Specially Designated Nationals list as the baseline control, with commercial chain-analytics providers layered in as the platform matures. A match routes the item to the compliance queue and, where technically possible, holds the funds pending review.

Merchant verification tiers

• Unverified — low monthly cap, no payout automation.
• Verified — standard caps after business verification.
• Enhanced — highest caps after enhanced due diligence.

Risk engine

Screening is rule-based first: payment velocity, amount anomalies, newly seen addresses and proximity to mixing services. Machine-learning triage is only ever advisory. No automated system is the final decision-maker over anyone's funds — a human reviews every hold.

Travel Rule

Where a jurisdiction applies the Travel Rule to custodial flows, the required originator and beneficiary information is collected and transmitted before the transfer is executed.

Audit trail

Every privileged action — fee changes, wallet edits, manual refunds and approvals — is written to an append-only, hash-chained audit log. A nightly reconciliation compares on-chain state against the ledger and raises an alert on any drift.

Reporting

Suspicious activity is reported to the competent authority in the operating jurisdiction within the statutory deadline. We do not notify the subject of a report where doing so is prohibited.