# AML Policy

> PsWallet AML / KYC / CFT Policy: user verification, transaction monitoring and freezes, source of funds, and sanctions.

## 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**](https://t.me/pswalletsupp)

For government/regulatory bodies:

- Email: [**legal@pswallet.org**](mailto:legal@pswallet.org)

## 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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Source: https://help.pswallet.org/en/documents/compliance-policy