AML/KYC & Restricted Use Notice
This document does not claim that the Company holds any specific licence or regulatory status unless such status is expressly stated by the Company. English is controlling; translations are for convenience.
1. Risk-Based Compliance Approach
1.1 The Platform implements Identity Verification status, configurable withdrawal thresholds, risk flags, audit records, and manual review points. The Company may apply additional AML, counter-terrorist-financing, sanctions, or fraud controls where configured or legally required. This Notice does not assert that every possible screening integration is active.
2. Identity Verification
2.1 Sumsub is the Company's current approved identity-verification provider. Identity-verification providers may change over time; this Notice describes the Company's approach to identity verification generally and is not conditioned on the continued exclusive use of any single provider.
2.2 Identity Verification may be required depending on flexible, non-numeric triggers, including:
- applicable-law requirements;
- transaction or cumulative-volume thresholds;
- sanctions screening;
- AML and financial-crime controls;
- fraud indicators;
- account or wallet risk signals;
- enhanced due diligence;
- other documented internal risk controls.
2.3 Triggers are configurable and not made public as fixed rules. No specific withdrawal amount, transaction threshold, or numeric trigger is fixed in this Notice. Thresholds are operational parameters the Company may adjust from time to time to respond to risk, and are not a legal commitment to any particular numeric value.
2.4 A User requests withdrawal of funds reserved in the Escrow smart contract on the BNB Smart Chain to a destination wallet. The implemented workflow applies the configured Identity Verification threshold, rejects ineligible requests, and records the request before it is processed on-chain. A request is not a guaranteed or immediate blockchain transfer.
2.5 Where enhanced due diligence applies, the Company may request additional information, including information about the source of funds or source of wealth involved in a User's activity on the Platform.
3. Travel Rule
3.1 Where applicable law requires it, the Company may collect, hold, or transmit originator and beneficiary information for covered transfers. Whether and how this applies to the Platform requires operator and legal confirmation before this Notice becomes effective.
4. Sanctions
4.1 The Company does not maintain or publish a fixed list of restricted countries. Sanctions exposure is assessed by reference to the applicable frameworks of:
- OFAC (U.S. Office of Foreign Assets Control);
- the European Union;
- the United Kingdom; and
- the United Nations.
4.2 The Company reserves the right to restrict access to the Interface where required by applicable law, without publishing a static list of restricted jurisdictions in this Notice.
5. Prohibited Use
5.1 Users must not use the Interface to: facilitate money laundering or terrorist financing; transact with a sanctioned person, entity, or jurisdiction where prohibited by applicable law; evade or attempt to evade Identity Verification, sanctions screening, or other controls described in this Notice; or provide false, misleading, or fraudulent information in connection with Identity Verification or any other Company control.
6. Effect of Restricted Access
6.1 Restriction or suspension can prevent off-chain marketplace, balance, Escrow, or withdrawal operations through the Interface. It does not reverse a blockchain transaction already confirmed through an expressly enabled on-chain mode, and the Company cannot sign a Wallet transaction for a User.
7. Recordkeeping and Lawful Disclosures
7.1 The Platform retains Identity Verification status and limited provider metadata, financial/audit records, and documented risk decisions. The exact retention schedule and any legally required reporting process remain subject to operator and legal approval. Records may be disclosed where legally required.
8. Cooperation With Competent Authorities
8.1 The Company will cooperate with competent regulatory, law-enforcement, and judicial authorities where legally required, including in response to lawful requests for information or in connection with a court order.
9. False Information and Evasion
9.1 Providing false information to circumvent Identity Verification, sanctions screening, or other controls described in this Notice is a material breach of the Terms of Service and may result in suspension or termination of access, and may be reported to competent authorities where legally required.
10. Privacy Cross-Reference
10.1 Information about how Identity Verification and screening data is collected, processed, and retained is described in the Privacy & Cookie Policy.
11. Updates to Controls
11.1 The Company may update its compliance controls, including Identity Verification triggers, identity-verification providers, and sanctions-screening practices, from time to time to respond to legal requirements and risk assessment, without necessarily republishing every operational detail in this Notice.