LEGAL / AML POLICY

Anti-money-laundering policy

Last updated 1 September 2026. A summary of how we screen, monitor and report. The full framework is issued with the merchant agreement.

AML / CTF POLICY

How we screen, monitor and report.

Our framework follows a risk-based approach to anti-money-laundering and counter-terrorist-financing obligations.

Onboarding

Every merchant is risk-scored before going live.

  • Identification and verification of the legal entity and its beneficial owners above 25%
  • Sanctions, PEP and adverse-media screening on owners, directors and the entity
  • Source-of-funds and business-model review, including traffic sources
  • Verification of any permits the vertical requires

Ongoing monitoring

Risk scores are reviewed at least annually and on any material change.

  • Transaction monitoring against merchant-specific baselines
  • Velocity, geography and ticket-size anomaly rules
  • Chargeback and refund ratio surveillance per MID
  • Screening re-run on every payout above threshold

Reporting and record-keeping

Suspicious activity is escalated and reported to the appropriate authority without tipping off.

  • Records retained for the statutory period
  • A named officer accountable for the framework
  • Annual independent review of controls
  • Staff training on AML and CTF at least yearly
OTHER DOCUMENTS

The rest of the legal set.

Each is a page of its own.

Terms and conditions

Scope, term, fees, settlement, reserves, prohibited activity, liability and termination.

Privacy policy

What personal data we hold, why, who we share it with, how long we keep it and the rights you can exercise.

Cookie policy

Every cookie we set, what it does, how long it lasts and how to change your choice.

QUESTIONS

Want the full documents first?

Ask and we will send the merchant agreement, AML framework and privacy notice before you apply.