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Anti-money-laundering policy

Prepaid vouchers are a known channel for fraud proceeds. Handling them responsibly is the condition of operating at all.

Draft — not legal advice, and not ready to publish

The controls described here match what the platform actually enforces, but a published AML policy is a regulatory document. This page must be drafted or reviewed by a lawyer qualified in United States and in every market you serve before the site goes live. The structure below is a starting point for that conversation, not a substitute for it.

Why this matters here specifically

Prepaid vouchers are bought with cash, carry no account holder, and transfer by passing a string of characters. That combination makes them useful to people who have obtained money by deception and need to move it — and it makes any business that converts them into crypto or bank transfers a natural target for exactly that traffic.

A service like this one is either a control point or a laundering channel. There is no neutral middle. The measures below are how we intend to be the first.

Customer due diligence

Every customer is identified before any settlement is released, and there is no anonymous tier. Below the published threshold — counted cumulatively over a rolling twelve months — we ask for a declared full name and country of residence, and no document. At or above it, a government identity document and a selfie are required, reviewed by a person and not only by software. Sanctions screening runs at every amount either way.

Above a cumulative threshold in any 30-day window we apply enhanced due diligence: proof of address and a declaration of the source of funds, reviewed and recorded before anything further settles. Because it is measured on cumulative volume, splitting amounts across orders does not avoid it.

Settlement destinations must belong to the verified customer. We refuse payouts to a third party's wallet, bank account or PayPal address.

Sanctions and PEP screening

Customers are screened against United Nations, OFAC, European Union and United Kingdom consolidated lists, and for politically exposed person status, before their first payout and on a fixed cadence thereafter. A potential match holds the order until a person adjudicates it. A confirmed match blocks the account permanently.

Transaction monitoring

We look for the patterns that distinguish laundering from ordinary use: the same payout destination appearing across unrelated accounts, the same identity document behind more than one profile, amounts repeatedly set just below a reporting threshold, sudden volume from a new account, and vouchers submitted faster than a person could plausibly have acquired them legitimately.

Anything that fires opens a case, and an open case freezes settlement for that customer until it is resolved.

Reports of fraudulently obtained vouchers

If an issuer, a bank, a police force or a victim reports a voucher as obtained by deception, the corresponding order is frozen immediately and no settlement is released. We cooperate with issuers and with law enforcement, including preserving records and responding to lawful requests.

If you were tricked into buying a voucher and handing over the code — the caller claiming to be from tech support, a tax office, a delivery company, an employer, or someone you met online — tell us as soon as you can through support, and report it to your local police. Speed is what determines whether funds can still be held.

Suspicious transaction reporting

Where we form a suspicion of money laundering or terrorist financing, we file a suspicious transaction report with the relevant financial intelligence unit within the statutory deadline. We are prohibited from telling the customer that a report has been filed, so an unexplained delay is not something support can comment on.

Records

Transaction records, identity documents, screening results and the decision trail behind every approval are retained for five years, as required under United States anti-money-laundering obligations. Every operator action that touches a voucher code, a customer document or a settlement is written to an append-only audit log.

Governance

Approving an order and releasing its settlement are separate actions that must be performed by different people. Compliance blocks cannot be overridden from the interface — clearing one means resolving the underlying fact, which is itself recorded.