Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

Last Updated: January 19, 2026

1. Introduction

ISV.me is committed to preventing money laundering, terrorist financing, and other financial crimes. This AML/KYC Policy outlines our procedures to ensure compliance with applicable laws and regulations.

2. Regulatory Framework

This policy complies with:

• Bank Secrecy Act (BSA)
• USA PATRIOT Act
• Financial Crimes Enforcement Network (FinCEN) regulations
• Office of Foreign Assets Control (OFAC) sanctions
• EU Anti-Money Laundering Directives
• Local anti-money laundering regulations in operating jurisdictions

3. Risk-Based Approach

We employ a risk-based approach to AML/KYC, categorizing users and transactions by risk level:

3.1 Low Risk

• Transactions under $1,000
• Users with verified identity
• Users with positive transaction history
• Standard KYC required

3.2 Medium Risk

• Transactions between $1,000 - $10,000
• New users with limited history
• Users from higher-risk jurisdictions
• Enhanced due diligence may be required

3.3 High Risk

• Transactions over $10,000
• Users from high-risk countries (FATF list)
• Politically Exposed Persons (PEPs)
• Unusual transaction patterns
• Enhanced KYC required

4. Customer Identification Program (CIP)

4.1 Required Information

For Individual Users:

• Full legal name
• Date of birth
• Residential address
• Government-issued ID number
• Email address and phone number

For Business Accounts:

• Legal business name
• Business registration number
• Business address
• Tax identification number (EIN/VAT)
• Beneficial ownership information
• Authorized representative details

4.2 Verification Methods

Standard Verification:

• Email verification (required for all)
• Phone number verification (optional)
• OAuth authentication (Google, Apple)

Enhanced Verification (for transactions over $1,000):

• Government-issued photo ID (passport, driver's license, national ID)
• Proof of address (utility bill, bank statement, less than 3 months old)
• Selfie verification with ID
• Video verification for high-value transactions

4.3 Verification Timeline

• Standard accounts: Email verification within 24 hours
• Enhanced verification: 1-3 business days
• High-risk verification: Up to 7 business days
• Expedited verification available for urgent transactions (additional fee may apply)

5. Transaction Monitoring

5.1 Automated Monitoring

We monitor all transactions for suspicious activity:

• Unusually large transactions
• Rapid succession of transactions
• Transactions inconsistent with user profile
• Structuring (breaking large transactions into smaller ones)
• Transactions involving high-risk jurisdictions

5.2 Red Flags

Transactions flagged for review include:

• Single transaction over $10,000
• Cumulative transactions over $25,000 in 30 days
• Sudden change in transaction patterns
• Use of multiple accounts from same IP/device
• Refusal to provide identification
• Suspicious domain names (potential illicit activity)
• Transactions to/from sanctioned countries

5.3 Review Process

• Automated flagging by our system
• Manual review by compliance team
• Additional documentation may be requested
• Transaction may be held pending review
• User notified of review status

6. Enhanced Due Diligence (EDD)

Enhanced due diligence required for:

6.1 High-Value Transactions

• Transactions exceeding $10,000
• Source of funds documentation required
• Purpose of transaction explanation
• Additional identity verification

6.2 Politically Exposed Persons (PEPs)

• Current or former senior government officials
• Close associates or family members of PEPs
• Enhanced screening and ongoing monitoring
• Senior management approval required

6.3 High-Risk Jurisdictions

Users from countries identified by FATF as high-risk require:

• Enhanced identity verification
• Source of funds documentation
• Ongoing transaction monitoring
• Periodic re-verification

7. Sanctions Screening

7.1 Screening Lists

We screen all users against:

• OFAC Specially Designated Nationals (SDN) list
• UN Sanctions List
• EU Sanctions List
• FATF high-risk jurisdictions
• Country-specific sanctions lists

7.2 Screening Frequency

• All new users screened at registration
• Existing users screened monthly
• Real-time screening for high-value transactions
• Lists updated daily

7.3 Positive Match Procedure

If a match is found:

• Account immediately suspended
• Transaction blocked
• Compliance officer review
• Report filed with authorities if required
• User notified (unless prohibited by law)

8. Suspicious Activity Reporting (SAR)

8.1 Reporting Threshold

We file SARs for:

• Transactions over $5,000 involving known or suspected criminal activity
• Transactions designed to evade BSA requirements
• No apparent legitimate business purpose
• Suspected terrorist financing (any amount)

8.2 SAR Filing Process

• Compliance officer reviews flagged activity
• SAR filed with FinCEN within 30 days
• Records maintained for 5 years
• User not notified of SAR filing

8.3 Suspicious Indicators

• Customer provides minimal or false information
• Multiple accounts with same identifying information
• Transactions with no apparent economic purpose
• Refusal to provide documentation
• Frequent changes of beneficiary information

9. Record Keeping

9.1 Records Maintained

• Customer identification documents: 5 years after account closure
• Transaction records: 10 years
• SAR supporting documentation: 5 years
• AML training records: 5 years
• Compliance audit reports: 7 years

9.2 Data Access

• Records accessible to authorized personnel only
• Available to regulators and law enforcement upon request
• Secure storage with encryption
• Regular backups maintained

10. Prohibited Activities

10.1 Strictly Prohibited

• Money laundering
• Terrorist financing
• Fraud or deceptive practices
• Transactions with sanctioned individuals or entities
• Structuring transactions to evade reporting
• Using platform for illegal purposes

10.2 Restricted Transactions

• Domains used for illegal activities
• Transactions involving sanctioned countries
• High-risk gambling or adult content domains
• Domains infringing intellectual property rights

10.3 Consequences

• Immediate account suspension
• Transaction reversal
• Funds frozen pending investigation
• Report to law enforcement
• Permanent ban from platform
• Legal action if warranted

11. Geographic Restrictions

11.1 Blocked Jurisdictions

We do not serve users from:

• Countries under comprehensive OFAC sanctions (e.g., Iran, North Korea, Syria, Cuba)
• FATF-identified high-risk jurisdictions with strategic deficiencies
• Jurisdictions where our operations would violate local law

11.2 Restricted Jurisdictions

Enhanced due diligence required for:

• Countries on FATF grey list
• High-risk tax havens
• Jurisdictions with weak AML enforcement

12. Training and Compliance

12.1 Staff Training

• Annual AML/KYC training for all employees
• Quarterly updates on regulatory changes
• Specialized training for compliance team
• Testing and certification required

12.2 Compliance Officer

• Designated AML compliance officer
• Direct reporting to senior management
• Authority to suspend suspicious transactions
• Liaison with regulatory authorities

12.3 Independent Audit

• Annual independent AML audit
• Testing of controls and procedures
• Review of SAR filings
• Recommendations for improvement

13. Customer Obligations

13.1 Users Must:

• Provide accurate and complete information
• Update information when changes occur
• Respond to verification requests promptly
• Not engage in prohibited activities
• Report suspicious activity they observe

13.2 Failure to Comply

• Account suspension until compliance achieved
• Transaction delays or cancellations
• Account closure for persistent non-compliance
• Possible reporting to authorities

14. Privacy and Confidentiality

• KYC information kept confidential per Privacy Policy
• Shared only with authorized service providers
• Disclosed to authorities when required by law
• Users not notified of SAR filings (as required by law)

15. Currency Transaction Reporting (CTR)

• Transactions over $10,000 reported to FinCEN (if applicable)
• Multiple transactions aggregating over $10,000 in 24 hours
• Form 8300 filed within 15 days
• Records maintained for 5 years

16. Third-Party Service Providers

16.1 Payment Processors

• Stripe Connect and PayPal conduct own AML/KYC
• We rely on their compliance programs for payment processing
• Additional verification may still be required

16.2 Identity Verification Services

• May use third-party ID verification services
• Services must meet our compliance standards
• Users consent to verification by clicking "Verify"

17. Ongoing Monitoring

• Periodic re-verification of high-risk accounts
• Transaction pattern analysis
• Continuous sanctions screening
• Review of user activity logs
• Updates to risk profiles

18. Charity Donation Monitoring

• Charity organizations vetted before listing
• Verification of legitimate charitable status
• Monitoring for diversion of funds
• Screening against terrorist financing lists
• Transparency in donation distribution

19. Updates to Policy

• Policy reviewed annually or when regulations change
• Updates posted on website
• Users notified of material changes
• Continued use constitutes acceptance

20. Contact Information

AML Compliance Officer:

• Email: compliance@isv.me
• Phone: [Compliance Hotline]
• Address: [Business Address]

Regulatory Inquiries:

• Email: regulatory@isv.me

Suspicious Activity Reporting:

• Internal: compliance@isv.me
• FinCEN: www.fincen.gov

21. Disclaimer

This policy does not create contractual obligations beyond our Terms of Service. We reserve the right to:

• Request additional information at any time
• Suspend or terminate accounts at our discretion
• Modify procedures based on risk assessment
• Refuse service without explanation when required by law

Summary

By using ISV.me, you agree to comply with this AML/KYC Policy and understand that failure to provide required information may result in account suspension or termination.