AML Policy
1. General Provisions
This AML / KYC / CFT Policy (hereinafter — the "Policy") is developed to ensure the safe, transparent, and lawful use of PsWallet services (hereinafter — "PsWallet", "the Platform", "we").
PsWallet adheres to international standards and best practices in the area of:
anti-money laundering (AML);
countering the financing of terrorism (CFT);
customer identification and verification (KYC).
PsWallet applies a risk-based approach (RBA) to minimize the risks of unlawful use of the Platform.
2. User Identification and Verification (KYC)
PsWallet has the right to initiate the KYC procedure in cases determined by internal security policies, partner requirements, or identified risks.
KYC may include:
collection and verification of personal data;
verification of identity documents;
checks against sanctions lists, PEP databases, and risk sources;
enhanced due diligence (EDD) for higher-risk users.
For conducting KYC, PsWallet uses a third-party provider — Sumsub.
Refusal to undergo KYC or to provide accurate information may result in restriction or termination of service.
3. Transaction Monitoring and KYT (Know Your Transaction)
PsWallet conducts continuous monitoring of users' transactions to detect operations related to:
money laundering;
financing of terrorism;
sanctions evasion;
fraudulent or other illegal activity.
Monitoring includes analysis of:
transaction patterns;
interaction with high-risk or sanctioned addresses;
use of mixers, anonymizing services, unlicensed platforms, and darknet resources.
4. Freezing of Incoming Transactions with High AML Risk
If an incoming transaction is assessed as high AML risk based on automatic or manual analysis, PsWallet has the right to temporarily freeze such a transaction until the completion of the review.
4.1. Possible User Actions
In the event of a transaction freeze, the user may choose one of the following options:
a) Return of funds to the sender The user has the right to initiate a return of funds to the sender's address with the deduction of a fixed fee in the amount of 15 (fifteen) US dollars, covering operational and compliance costs.
b) Confirmation of the source of funds The user has the right to contact PsWallet support and provide documents confirming the lawful source of funds (SOF / SOW). Based on the review by PsWallet compliance, the transaction may be unfrozen.
4.2. No Action by the User
If the user:
does not choose any of the available options;
refuses to interact with support;
does not provide the requested documents within a reasonable time,
PsWallet reserves the right to destroy (permanently write off) frozen funds in order to comply with AML / CFT requirements and minimize regulatory risks.
The decision to destroy funds is final and not subject to appeal.
5. Source of Funds (SOF) and Source of Wealth (SOW)
PsWallet may request confirmation of the legality of the origin of funds in cases of:
detection of high-risk transactions;
exceeding normal transaction volumes;
suspicion of circumventing AML/KYC procedures;
conducting EDD checks.
Supporting documents may include bank statements, income certificates, contracts, and other legal documents.
6. Sanctions and Restrictions
PsWallet screens users against international sanctions lists, PEP databases, and sources of adverse information.
Upon identification of risks, PsWallet may:
restrict account access;
freeze funds;
refuse service.
The list of prohibited jurisdictions may change without prior notice.
7. Underage Users
PsWallet does not provide services to persons under 18 years of age.
If an underage user is detected, account access will be restricted and funds may be frozen.
8. Prohibition of Alternative Verification
The use of third-party documents, transfer of accounts, and impersonation of another person are prohibited.
Violations may result in immediate account suspension and freezing of funds.
9. Interaction with Government Authorities
PsWallet cooperates with competent authorities and may disclose information in response to lawful requests, as well as terminate service to users suspected of illegal activity.
10. Data Protection and Privacy
Personal data is processed solely for the purpose of fulfilling AML / KYC / CFT requirements and is protected by technical and organizational measures.
11. Contacts and Support
For questions regarding AML / KYC, transaction freezes, and source of funds verification, you can contact us:
Telegram: @pswalletsupp
For government/regulatory bodies:
Email: [email protected]
12. Policy Updates
PsWallet reserves the right to modify this Policy unilaterally. The current version is published on the website pswallet.org. Use of PsWallet after updates constitutes acceptance of the new version.
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