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 and regulations and the recommendations of 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 binding on all personnel and Users. These procedures determine the Service's approach to the onboarding of Users, transaction monitoring and risk management.
The compliance function ensures that the Service's operations are conducted in accordance with internationally recognised AML/CFT standards, and that User information and documentation are kept up to date and comply 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 US tax residents;
- legal entities incorporated, registered or effectively managed in the United States;
- legal entities controlled by US persons.
By using the Website and the Services, the User represents and warrants that the User is not a United States Person and does not act on behalf of, or for the benefit of, a United States Person.
The Service applies reasonable measures to prevent access to the Services by United States Persons and reserves the right to refuse service, suspend access or close Personal Cabinets where such status is suspected or established.
3. AML/KYC Obligations of the User
By becoming a User of the Service, the User irrevocably agrees as follows:
- the User shall comply with the Service's AML and KYC requirements throughout the entire term of the relationship with the Service and, upon request, shall provide such additional documents and information as may reasonably be required by the Service, including completed KYC questionnaires;
- the User acknowledges and agrees that the Service may disclose information about the User to financial institutions, regulators and law enforcement authorities where required by applicable law, and expressly consents to such disclosure;
- 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. Tokenised Cards. For the issuance of tokenised 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 in the Service's lists of prohibited or high-risk email domains. Where this requirement is not met, the Service may refuse or revoke the issuance.
4. Prohibited Jurisdictions
The Service does not permit the use of the Services for payments relating to goods, services or rights where the seller or counterparty is incorporated in, or operates from, a jurisdiction subject to comprehensive international sanctions or classified as high-risk.
The designation of jurisdictions as restricted below reflects comprehensive international sanctions and/or the Service's own commercial risk assessment.
4.1. Restricted Countries (Services Not Provided)
The Service does not provide the Services to US 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
The Services are also not available in the following regions:
Crimea; Donetsk; Kherson; Luhansk; Sevastopol; Zaporizhzhia.
4.3. High-Risk Jurisdictions (Enhanced Due Diligence)
The provision of the Services in the following jurisdictions is subject to additional verification, enhanced due diligence and possible limitations on the scope or volume of the Services:
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 / 5967 — Direct Marketing – Outbound Telemarketing; Adult Content and Services / Inbound Telemarketing
- 6010 / 6011 / 6012 / 6050 / 6051 — Quasi-Cash, ATM transactions, financial institution transfers, and cryptocurrency-related operations (except plastic cards)
- 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
- 8398 — Charitable and Social Service Organizations
- 8651 — Political Organizations
- 8661 — Religious Organizations
- 9405 — U.S. Federal Government Agencies or Departments
- 9406 — Government-Owned Lotteries (Non-U.S. region)
For certain card types, purchases from specific merchants under MCC 4121 (Taxicabs and Limousines) and 5947 (Gift, Card, Novelty and Souvenir Shops) may also be unavailable or partially restricted.
Any breach of the rules of Visa, Mastercard or the policies of the Service's platform may result in immediate suspension or closure of the Personal Cabinet.
6. Sanctions Screening
The Service reserves the right to screen 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 Personal Cabinets where an affiliation with sanctioned individuals or entities, or with prohibited governmental or law enforcement bodies, is identified.
7. Transaction Monitoring and Investigations
The User warrants the lawful origin of, ownership of and right to use all assets transferred to the User's Accounts.
Where transactions are deemed suspicious, involve unverified sources, display indicators of fraud or otherwise give rise to compliance concerns, the Service reserves the right to:
- conduct internal investigations;
- suspend, block or close Personal Cabinets and Accounts;
- cancel or reverse transactions where permitted by law;
- restrict the functionality of the Personal Cabinet pending completion of the review.
The Service may request additional information or documents, including proof of identity, residence and source of funds. Failure or refusal to provide the requested information may result in suspension or closure of the Personal Cabinet.
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 suspension or closure of the Personal Cabinet, shall not give rise to any civil liability of the Service.
The Service shall not be obliged to inform Users or third parties of 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 information purposes and sets out the general principles of the Service's AML and KYC framework. The Service maintains internal AML/KYC procedures that may supplement or extend 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 sole discretion of the Service.