GoGoCard

Updated5 months ago

AML/KYC Policy

1. General Provisions

In order to ensure compliance with applicable international standards on anti‑money laundering and countering the financing of terrorism (AML/CFT), the Service operates in accordance with applicable laws, regulations, and recommendations issued by the Financial Action Task Force (FATF).

The Service has established internal compliance procedures, including Anti‑Money Laundering (AML) and Know Your Customer (KYC) measures, which are mandatory for all personnel and Users. These procedures define the Service's approach to onboarding, transaction monitoring, and risk management.

The compliance function ensures that the Service's operations are conducted in line with internationally recognised AML/CFT standards, and that User information and documentation are kept up to date and compliant with applicable legal requirements.

2. Exclusion of United States Persons

The Service does not provide services, directly or indirectly, to United States Persons.

For the purposes of this Policy, a United States Person includes, without limitation:

  • citizens of the United States;
  • lawful permanent residents of the United States (Green Card holders);
  • persons considered U.S. tax residents;
  • legal entities incorporated, registered, or effectively managed in the United States;
  • legal entities controlled by U.S. persons.

By using the Service's Website and Services, the User represents and warrants that they are not a United States Person and do not act on behalf of, or for the benefit of, a United States Person.

The Service applies reasonable measures to prevent access to its Services by United States Persons and reserves the right to refuse service, suspend access, or close accounts where such status is suspected or identified.

3. AML / KYC Obligations of the User

By becoming a User of the Service, the User irrevocably agrees to the following:

  • The User is required to comply with the Service's AML and KYC requirements throughout the entire period of the relationship with the Service. Upon request, the User shall provide additional documents and information as reasonably required by the Service, including completion of KYC questionnaires;
  • The User acknowledges and agrees that the Service may share information about the User with financial institutions, regulators, and law enforcement authorities where required by applicable law, and expressly consents to such disclosures;
  • The User undertakes to comply with applicable laws and regulations aimed at combating money laundering, terrorist financing, financial fraud, and other illicit financial activities.

3.1. Tokenized cards. For the issuance of tokenized cards (cards added to third‑party wallets such as Apple Pay or Google Pay), the User's email address must not belong to a domain included on the Service's prohibited or high‑risk email lists. The Service may refuse or revoke issuance where this requirement is not met.

4. Prohibited Jurisdictions

The Service does not allow the use of its Services for payments related to goods, services, or rights where the seller or counterparty is incorporated in, or operates from, jurisdictions subject to comprehensive international sanctions or high‑risk classifications.

Restricted‑jurisdiction designations below reflect comprehensive international sanctions and/or the Service's own commercial risk assessment.

4.1. Restricted Countries (Services Not Provided)

The Service does not provide Services to U.S. persons (as defined under FATCA/OFAC regulations) or to persons or entities located in, or operating from, the following jurisdictions:

Afghanistan; Haiti; Iraq; Democratic People's Republic of Korea (North Korea); Myanmar (Burma); Nigeria; Palestine; Republic of Somaliland; Somalia; South Sudan; Sudan; Syria; United States of America; Yemen.

4.2. Restricted Regions

Services are also unavailable in the following regions:

Crimea; Donetsk; Kherson; Luhansk; Sevastopol; Zaporizhzhia.

4.3. High‑Risk Jurisdictions (Enhanced Due Diligence)

Services in the following jurisdictions are subject to additional verification, enhanced due diligence, and possible limitations on the scope or volume of Services provided:

Belarus; Central African Republic; Cuba; Democratic Republic of the Congo; Ethiopia; Guinea‑Bissau; Iran; Lebanon; Libya; Mali; Nicaragua; Russia; Ukraine; Venezuela; Zimbabwe.

5. Prohibited Activities and MCC Codes

The following merchant category codes (MCC) and related activities are strictly prohibited on the Service's platform:

  • 4829 — Money Transfers / Wire Transfers
  • 5944 — Jewelry, Watches, Clocks, and Silverware Stores
  • 5966 — Direct Marketing – Outbound Telemarketing
  • 6010 / 6011 / 6012 / 6050 / 6051 — Quasi‑Cash, ATM transactions, financial institution transfers, and cryptocurrency‑related operations
  • 6211 — Security Brokers and Dealers
  • 6540 — Prepaid Card Loads and Purchases
  • 7273 — Dating and Escort Services
  • 7297 — Massage Parlors
  • 7800 / 7801 / 7802 — Government‑Owned Lotteries, Licensed Online Casinos, Government‑Licensed Horse/Dog Racing
  • 7995 — Gambling, Betting, and Casino Operations
  • 8651 — Political Organizations
  • 8661 — Religious Organizations
  • 9406 — Government‑Owned Lotteries (Non‑U.S. region)

Any violation of Visa, MasterCard, or the Service's platform policies may result in immediate suspension or termination of the account.

6. Sanctions and Screening

The Service reserves the right to conduct checks on all new and existing Users against applicable sanctions lists, including those maintained by the United Nations, the European Union, the United Kingdom, Canada, and other relevant international bodies.

The Service may also refuse service, suspend, or close accounts where affiliation with sanctioned individuals, entities, or prohibited governmental or law enforcement bodies is identified.

7. Transaction Monitoring and Investigations

Users guarantee the lawful origin, ownership, and right to use all assets transferred to their accounts.

Where transactions are deemed suspicious, involve unverified sources, display indicators of fraud, or otherwise raise compliance concerns, the Service reserves the right to:

  • conduct internal investigations;
  • suspend, block, or close accounts;
  • cancel or reverse transactions where permitted by law;
  • restrict account functionality pending completion of review.

The Service may request additional information or documentation, including proof of identity, residence, and source of funds. Failure or refusal to provide requested information may result in account suspension or closure.

8. Preventive Measures and Liability

The Service may refuse to execute transactions that it reasonably considers suspicious or non‑compliant. The application of preventive measures, including account suspension or closure, does not give rise to civil liability of the Service.

The Service is not obliged to inform Users or third parties about the specific measures taken, the reasons for such measures, or the existence of any suspicions or reports filed in accordance with AML/CFT legislation.

9. Final Provisions

This Policy is provided for informational purposes and outlines the general principles of the Service's AML and KYC framework. The Service maintains internal AML/KYC procedures that may supplement or expand upon this Policy.

This AML & KYC Policy forms an integral part of any agreement between the User and the Service. Non‑compliance with this Policy may result in termination of the contractual relationship at the Service's sole discretion.