AML/CTF and Sanctions Policy

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

In short: Paysell will not be used to launder money, finance terrorism or evade sanctions. Paysell applies a risk-based approach: it may ask you at any time to prove who you are, where your funds come from and what your business does, and it may hold funds, delay or refuse a withdrawal, suspend a shop or report to the authorities. This policy describes the controls Paysell applies today and the controls it is building; it does not claim more than exists.

1. Purpose and scope#

1.1 This policy states how [[Company legal name]] ("Paysell") manages the risk that the Services are used for money laundering, terrorist financing, proliferation financing or sanctions evasion.

1.2 It applies to every merchant, every shop, every account holder and every member of Paysell staff, and to all activity conducted through the merchant cabinet and the API.

1.3 It is a statement of Paysell's own standards and reserved rights. Paysell's regulatory position is set out separately and honestly in the Regulatory Status Statement; nothing in this policy asserts that Paysell holds a license or registration it does not hold.

1.4 Merchants remain responsible for their own anti-money-laundering obligations under the law of their own jurisdiction. Paysell's controls do not discharge them.

2. What Paysell does today, and what it is building#

Paysell states its position plainly so that merchants and counterparties are not misled.

Where this policy says Paysell "applies" a control, it refers to the manual and procedural controls in place. Where it says Paysell "may apply" or "is building", the control is a reserved right or planned work, not a running system. This table will be updated as controls are implemented; it is the honest reference point for anyone assessing Paysell.

3. Risk-based approach#

3.1 Paysell assesses risk across four dimensions: merchant risk (who owns and controls the business, its structure and history), business risk (the category of goods or services, whether it needs a license, and whether it is on the restricted list), geographic risk (where the merchant, its owners and its buyers are located), and transaction risk (volume, size, velocity, patterns and counterparty addresses).

3.2 The level of due diligence applied is proportionate to the assessed risk. A low-turnover merchant selling a simple digital product is treated differently from a high-turnover gaming operator.

3.3 Categories requiring enhanced review are listed in the Acceptable Use Policy. Restricted countries and territories are addressed in Restricted Jurisdictions.

3.4 The risk assessment is reviewed periodically and after any material change to the Services, to the supported assets or to the merchant base.

4. Merchant due diligence#

4.1 Paysell may at any time require a merchant to complete verification as described in the Merchant Verification (KYC/KYB) Policy, including identification of the merchant, its legal form, its beneficial owners and the people who control it.

4.2 Verification may be required before a first withdrawal, when cumulative turnover exceeds a threshold set by Paysell, when a merchant enters a restricted category, when activity does not match what was declared at registration, or on any suspicion.

4.3 Paysell may ask about source of funds and source of wealth, about the nature of the underlying business, about the merchant's own licenses, and about specific transactions.

4.4 Paysell may decline to onboard, or may exit, any merchant at its discretion, and is not obliged to give reasons.

5. Sanctions#

5.1 Paysell will not knowingly provide the Services to, or process transactions for the benefit of, a person or entity subject to sanctions, or a person located in or ordinarily resident in a comprehensively sanctioned country or territory.

5.2 Merchants warrant on a continuing basis that they, their owners and their controllers are not sanctioned and are not owned or controlled by a sanctioned person, and that they will notify Paysell immediately if that changes.

5.3 Paysell is building automated screening of merchants, beneficial owners and blockchain addresses against public sanctions lists. Until that is in production, screening is performed manually and on a case-by-case basis, which means it is not comprehensive. Merchants must not rely on Paysell's screening as a substitute for their own.

5.4 Where a sanctions concern arises, Paysell may freeze the relevant balance, block withdrawals, terminate the relationship, and make any report required by law.

6. Transaction risk indicators#

Paysell treats the following as indicators that warrant closer examination. The list is illustrative, not exhaustive, and no single indicator is proof of wrongdoing.

• Turnover that materially exceeds what the merchant declared at registration, or that appears suddenly after a dormant period.
• A pattern of transactions structured just below a known review threshold.
• Many payments of identical amounts from many addresses in a short period, without a matching commercial explanation.
• Invoices that are systematically overpaid, or payments arriving for expired invoices.
• A merchant website that does not sell anything identifiable, is inaccessible, is a placeholder, or does not match the declared business.
• A merchant that changes its business category, website or withdrawal address shortly after receiving a large payment.
• Withdrawal addresses associated with mixers, tumblers, "cash-out" services or high-risk exchanges.
• Reluctance to answer routine verification questions, incomplete or altered documents, or answers that change between requests.
• Requests to route funds to an address that the merchant does not claim to control, or to split withdrawals across many unrelated addresses.
• Buyers or merchants located in or connecting from restricted jurisdictions.
• Complaints or law enforcement contact concerning a merchant's activity.

7. Measures Paysell may take#

7.1 Where a concern arises, Paysell may, without prior notice and for as long as the concern reasonably requires:

• request further information, documents or explanations;
• delay, limit or refuse a withdrawal;
• place a hold on all or part of a balance;
• suspend invoice creation, suspend a shop, or suspend an account;
• terminate the relationship under the Terms of Service;
• report the matter to the competent authority.

7.2 Paysell will act proportionately and will release a hold when the concern is resolved. A hold is not a finding of wrongdoing.

7.3 Paysell does not accept instructions to reverse a blockchain transaction, because that is technically impossible. Funds already sent cannot be recalled.

8. Reporting and no tipping-off#

8.1 Where Paysell suspects that funds are the proceeds of crime, or are connected to terrorist financing or sanctions evasion, it will make the reports required by the law applicable to it, to [[Reporting authority / Financial Intelligence Unit]] in [[Jurisdiction]].

8.2 No tipping-off. Where a report has been made or is contemplated, Paysell and its staff must not disclose that fact, or the content of the report, to the merchant or to any third party, except as permitted by law. A merchant may therefore receive a hold or a refusal without a detailed explanation. This is not evasiveness; it is a legal requirement in most jurisdictions.

8.3 Paysell will respond to lawful requests from law enforcement, regulators and courts, and will provide the records described in section 9.

9. Record keeping#

9.1 Paysell retains records of merchant identification and verification material, transaction records, correspondence, internal escalations and decisions, and reports made to authorities.

9.2 Records are retained for at least [[Record retention period — e.g. 5 years]] from the end of the business relationship or from the date of the transaction, whichever is later, or longer where the law requires or an investigation is open.

9.3 Records are kept in a form that allows a transaction to be reconstructed and produced to an authority on request. Access is restricted by role, and administrative actions are written to an audit log.

9.4 Retention under this policy overrides a deletion request made on data protection grounds where the law permits; see the Privacy Policy.

10. Governance, staff and training#

10.1 Responsibility for this policy sits with [[Compliance officer name / role]], who is the point of contact for compliance matters and for authority requests, and who may escalate to [[Senior management / director]].

10.2 Staff with access to merchant data and transactions hold defined roles in the cabinet (client, support, manager, admin) with access limited to what the role requires. Support and manager roles may not release funds; withdrawal approval is restricted.

10.3 Staff must escalate any suspicion internally without delay and must not investigate it independently, discuss it with the merchant, or delete related records.

10.4 Staff receive training on this policy on joining and at least annually, covering risk indicators, escalation and the tipping-off prohibition. Training records are kept.

10.5 This policy is reviewed at least annually, and after any material change to the Services or the applicable law. The current version is published at https://paysell.me/legal.

11. Merchant cooperation#

11.1 Merchants must respond to verification and information requests fully, accurately and within the time stated in the request, which will normally be [[Response deadline — e.g. 10 business days]].

11.2 Failure to respond, an incomplete or false response, or the submission of altered documents may lead to suspension, a continued hold and termination.

11.3 Providing false information to Paysell may itself be a criminal offence in the merchant's jurisdiction and may be reported.

Contact#

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

• Compliance, verification and source-of-funds questions: [[Compliance email]]
• Law enforcement and regulator requests: [[Legal email]]
• General support: [[Support email]] or a ticket in the merchant cabinet