1. Our approach
Anti-money-laundering controls exist to stop criminal proceeds moving through a financial service. The usual method is to identify the customer. We have chosen a different one, and it is worth stating plainly what it is and what it is not.
We apply a risk-based approach built on three properties of this specific product:
- Funds are traceable on entry. Every deposit arrives on a public blockchain and carries its own history. That history is often more informative than a photograph of a passport.
- Funds cannot leave to a third party. A balance can only be spent through a card at a merchant. There is no withdrawal to a nominated address and no transfer between accounts, so the Service cannot be used as a layering step.
- Amounts are bounded. Deposits are capped and balances are small by design.
This does not make the Service anonymous to law enforcement, and we do not present it as such.
2. Screening every deposit
Before a deposit is credited, the originating address is screened. We check it against:
- sanctions lists we are required to apply, including designated wallet addresses;
- blockchain risk analytics, which score an address by its exposure to darknet markets, ransomware, known thefts, mixers and sanctioned entities.
A deposit from an address that fails screening is not credited. It is frozen pending review, and where the law requires it, reported. We may be prohibited from telling you that a report was made.
3. Ongoing monitoring
Screening at entry is not enough on its own, so account behaviour is monitored for patterns that do not fit ordinary card use. Among them:
- deposits structured just below a threshold;
- rapid load-and-spend cycles with no consumption pattern;
- many accounts sharing an infrastructure fingerprint;
- spend concentrated on merchant categories associated with resale of stored value;
- card testing — many small authorisations in a short window.
A pattern is a reason to look, not a verdict. Where a review is inconclusive we may ask you for information about a specific transaction, restrict the account, or close it.
4. Sanctions
We do not make the Service available where doing so would breach sanctions. We screen deposit addresses against applicable designated-persons and designated-address lists, and we block traffic from comprehensively sanctioned jurisdictions.
You confirm, each time you use the Service, that you are not a designated person and are not acting for one. A match results in immediate suspension and, where required, a report and the freezing of funds.
5. Limits as a control
Where other services use documents, we use bounds. Deposits are capped at $100,000 each, accounts hold at most 5 cards, and funds can leave only as card payments.
We may lower a limit for an individual account where the risk profile warrants it. We will tell you that a limit has changed; we will not always be able to tell you why.
6. No route to third parties
This deserves its own section because it is the single most important control in the design.
There is no way to move value out of the Service to a person you nominate. No withdrawal to a crypto address, no bank transfer, no account-to-account transfer, no gifting of a balance. Value enters as a deposit and leaves as a payment to a merchant.
Money laundering requires placement, layering and integration. A service with one entrance and one exit, where the exit is a merchant terminal, is a poor instrument for the second step.
The daily interest we pay under section 9 of the Terms does not change that. It is credited from our own reserve to a balance that is already yours, it never arrives from or leaves toward a third party, and it is subject to the same single exit. A suspended account accrues nothing.
7. Prohibited activity
Consistent with the Terms of Service, the Service may not be used in connection with money laundering, terrorist financing, sanctions evasion, fraud, child sexual abuse material, human trafficking, or the unlawful sale of weapons or controlled substances.
We also refuse deposits knowingly derived from ransomware payments, exchange or bridge exploits, and addresses attributed to a state-sponsored theft.
8. Reporting and cooperation
Where we form a suspicion that funds are the proceeds of crime, we file a report with the competent financial intelligence unit. The law usually forbids us from telling the customer that we have done so, and we comply with that prohibition.
We respond to lawful requests from law enforcement. We provide what we hold — which, by design, is an email address, a balance, a transaction history and blockchain identifiers. We cannot provide identity documents, because we never collected any. We do not volunteer data absent a lawful request.
9. Governance
Responsibility for this policy sits with our compliance function, which is independent of commercial objectives and has authority to suspend an account without commercial sign-off.
The policy is reviewed at least annually, and sooner where the law, the product or the threat landscape changes. Staff with access to account data receive AML training on joining and annually thereafter. Screening decisions and their reasons are recorded.
10. Reaching compliance
If your account has been restricted and you believe it is a mistake, raise it from that account — a restricted account can still be signed in to. Explaining a specific transaction, what it was for and where the funds came from, resolves most reviews.
Law enforcement requests must be served through the appropriate legal channel, with the legal basis stated. We respond to what is lawfully required of us and to nothing beyond it. As section 8 sets out, what we hold is an email address, a balance, a transaction history and blockchain identifiers.