Merchant Verification (KYC/KYB) Policy

Version 1.0 · Effective [[Effective date]] · Last updated [[Effective date]]

In short: You can register with just an e-mail address, but Paysell may ask you to verify your identity and your business at any time — and normally will before your first withdrawal, when your turnover grows, or if your business falls into a restricted category. Verification is currently a manual review of documents you send through a support ticket. If you refuse or cannot verify, withdrawals stay blocked and the account may be closed.

1. Purpose#

1.1 This policy explains how [[Company legal name]] ("Paysell") verifies the identity of merchants (Know Your Customer) and of merchant businesses (Know Your Business), when verification is triggered, what may be requested and what happens if a merchant does not comply.

1.2 It supports the AML/CTF and Sanctions Policy and forms part of the Terms of Service.

1.3 Current state. Verification today is a manual process: Paysell reviews documents submitted through a support ticket in the merchant cabinet. There is no automated identity verification, no automated document authentication and no automated watchlist screening. Paysell is building these capabilities and will update this policy when they are live. Merchants should not assume that another merchant on the platform has been verified.

2. Verification tiers#

2.1 Tiers describe the depth of due diligence, not a legal status. Paysell may require Tier 2 material from any merchant if the circumstances warrant it, and may set individual conditions on any account.

2.2 A merchant that has completed a tier is not thereby approved permanently. Verification is refreshed periodically and on any material change.

3. What may be requested#

3.1 Individual merchants and representatives#

• Full legal name, date of birth, nationality and residential address.
• A government-issued photo identity document (passport, national identity card or driving license), valid and fully legible.
• Proof of address issued within the last three months (utility bill, bank statement, government correspondence).
• A selfie or short video holding the identity document, or a live liveness check, where the risk warrants it.
• Confirmation that the person is authorized to act for the business.

3.2 Companies and other legal entities#

• Certificate of incorporation or registration, and the current registration number.
• Registered address and principal place of business.
• Constitutional documents (articles, memorandum, partnership agreement or equivalent).
• Register of directors and shareholders, or an equivalent extract from a company register.
• Identification of each beneficial owner holding [[Beneficial ownership threshold — e.g. 25%]] or more, and of anyone otherwise exercising control, each verified as in section 3.1.
• Evidence of authority for the person acting (board resolution, power of attorney or equivalent).
• Tax or VAT number where one exists.

3.3 The business itself#

• A working website that matches the declared business, with visible terms, pricing, contact details and refund policy.
• A description of the goods or services, the delivery model and the target markets.
• Every license, registration or authorization the business requires — for example a gambling license for iGaming, a financial services authorization for trading platforms, a pharmacy license for medicines — with the issuing authority and the license number.
• Evidence of age verification and content controls for adult businesses.
• Expected and actual monthly turnover, average order value and refund rate.
• Details of any prior payment provider and the reason the relationship ended.

3.4 Funds and transactions#

• Source of funds for the business and source of wealth for its owners.
• Explanation and supporting documents for a specific transaction, including the underlying order.
• Confirmation of ownership and control of a withdrawal address.
• Bank or accounting records where the business also handles fiat.

Paysell will request only what is proportionate to the risk, and will explain what is needed unless a legal restriction, such as the tipping-off prohibition, prevents it.

4. Verification triggers#

Verification is required or may be required when:

• a merchant requests its first withdrawal;
• cumulative received volume or withdrawal volume exceeds a threshold set by Paysell (currently [[Turnover threshold — e.g. 10,000 USDT in 30 days]]);
• a single incoming payment exceeds the manual review thresholds in the Fee Schedule and Limits (500 TON / 2,000 USDT);
• the shop belongs to a restricted category under the Acceptable Use Policy;
• the merchant, its owners or its buyers are connected to a jurisdiction on the Restricted Jurisdictions list;
• activity does not match what was declared at registration;
• a risk indicator listed in the AML/CTF and Sanctions Policy is present;
• there is a complaint, a third-party claim or contact from an authority;
• the business, its website, its ownership or its withdrawal address changes materially;
• a periodic refresh falls due — at least every [[Refresh period — e.g. 24 months]] for standard merchants and [[Enhanced refresh period — e.g. 12 months]] for enhanced-risk merchants;
• at any other time, at Paysell's discretion.

5. How verification works#

5.1 Paysell opens a support ticket in the merchant cabinet, or contacts the registered e-mail address, stating what is required and the deadline, normally [[Response deadline — e.g. 10 business days]].

5.2 Documents must be submitted through the cabinet ticket. Do not send identity documents over social media or messaging apps; Paysell will never ask for documents there, nor for your password, TOTP code, recovery codes or API keys.

5.3 Documents must be complete, in color, unedited, with all four corners visible and all text legible. Paysell may reject a document that is expired, cropped, redacted or altered, and may ask for a certified translation of a document not in [[Accepted document languages — e.g. English]].

5.4 A Paysell reviewer checks the documents against the information on file, against the merchant's website and against public sources. Paysell may seek clarification and may repeat the request.

5.5 Paysell aims to complete a review within [[Verification turnaround — e.g. 5 business days]] of receiving a complete submission, but does not guarantee a timeframe.

5.6 The outcome is recorded in the merchant's file, together with the reviewer's decision and the reasons, and is written to the audit log.

6. Outcomes#

7. Consequences of not verifying#

7.1 A merchant that does not respond, responds incompletely, or refuses to verify will not be able to withdraw. Balances stay recorded but locked.

7.2 Paysell may suspend invoice creation and the shop, and may terminate the relationship under the Terms of Service.

7.3 Where documents are falsified or the information is materially untrue, Paysell will terminate the relationship, may retain funds pending an investigation, and may report the matter to the competent authority. Providing false information may be a criminal offence in the merchant's jurisdiction.

7.4 On termination, a lawfully held balance is released to a verified merchant once the concern is resolved. Where a merchant cannot be verified at all, Paysell will deal with the balance as required by applicable law and will act on the direction of a competent authority where one is given.

7.5 A declined verification does not entitle the merchant to a refund of fees already charged.

8. Data protection#

8.1 Verification data is personal data. Paysell processes it as controller to meet its legal, regulatory and risk-management obligations, on the legal bases described in the Privacy Policy.

8.2 Access is restricted to staff whose role requires it. Access is logged.

8.3 Verification records are retained for at least [[Record retention period — e.g. 5 years]] after the end of the business relationship, as required by the AML/CTF and Sanctions Policy. This retention takes precedence over an erasure request where the law permits.

8.4 Verification data is not used for marketing and is not sold or shared other than with sub-processors, professional advisers and authorities as described in the Privacy Policy and the Data Processing Agreement.

9. Merchant obligations#

9.1 Keep your registered details, website, business description and beneficial ownership information accurate and current, and tell Paysell within [[Notification period — e.g. 14 days]] of a material change.

9.2 Do not open a second account to avoid a verification request or a suspension. Doing so is a breach of the Terms of Service and will lead to closure of every related account.

9.3 Do not process payments for a third party through your shop. Each merchant must be the party that actually sells the goods or services.

10. Changes#

Paysell may amend this policy, in particular as automated verification is introduced. The current version, with its version number and effective date, is published at https://paysell.me/legal.

Contact#

[[Company legal name]], [[Registered address]], [[Jurisdiction]]

• Verification and document submission: a ticket in the merchant cabinet, or [[Compliance email]]
• General support: [[Support email]]
• Data protection questions: [[DPO email]]