AML/CFT & KYC/KYB POLICY

Effective upon publication

1. Purpose

This Policy establishes PayPlay's framework to prevent money laundering, terrorist financing, and related financial crimes. It governs our Know Your Customer (KYC) and Know Your Business (KYB) processes and compliance obligations across all jurisdictions in which we operate.

2. Prohibited Activities

PayPlay does not process transactions related to the following:

  • Drugs, controlled substances, and drug paraphernalia
  • Weapons, explosives, and hazardous materials
  • Sexually explicit content or services
  • Pyramid schemes, multi-level marketing, and deceptive investment practices
  • Intellectual property infringement or counterfeit goods
  • Sanctioned entities or politically exposed persons (PEPs)
  • Anonymization services (e.g. crypto mixers/tumblers)
  • Darknet marketplace transactions
  • NFT wash trading or fraudulent token schemes
  • AI-generated fraud, deepfake scams, or synthetic identity fraud
  • Unlicensed financial services or unauthorized remittance
  • Hacking tools, stolen data, or cybersecurity exploits
  • Cloud-mining transactions
  • Any activity outside PayPlay's sole risk appetite

3. Sanctions Policy

PayPlay screens all users against global sanctions lists prior to onboarding and on an ongoing basis. Transactions involving sanctioned parties are frozen immediately, and affected accounts may be suspended or terminated. Screening covers:

  • UN, EU, UK (HMT), and Swiss (SECO) Sanctions
  • US OFAC SDN List, BIS, and State Department Debarred Lists
  • Australian and Canadian Sanctions Lists
  • INTERPOL Wanted List

4. High-Risk & Prohibited Jurisdictions

PayPlay services are unavailable to citizens or residents of the following jurisdictions. This list is subject to change without notice — users are responsible for checking the current version on our website:

Afghanistan, American Samoa, Australia*, Belarus, Canada, Guam, Iran, Kosovo, Libya, Myanmar, North Korea, Northern Mariana Islands, Palestine, Puerto Rico, Russian Federation, Somalia, South Sudan, Sudan, Syria, Transnistria, Trinidad and Tobago, Turkey (N. Cyprus), Ukraine (occupied territories), USA, Venezuela, Western Sahara, Yemen.

* Includes all territories and temporarily occupied regions as designated by applicable regulatory bodies.

5. Record-Keeping

All transaction records, KYC and KYB documents, and user communications are retained for a minimum of 5 years from the date of the relevant transaction or end of the business relationship, extendable to 8 years upon regulatory request. Records include identity verification documents, trading activity logs, and all user correspondence.

6. Policy Updates

This Policy is effective upon publication and may be updated at any time. Continued use of PayPlay services constitutes acceptance of the current Policy. If you disagree with this Policy, please discontinue use of our services.

Questions? Contact our AML Department: [email protected]