Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Regulations for the 24PayBanks Platform

1. General provisions and objectives of compliance

24PayBanks operates in strict compliance with international security and financial crime prevention standards. Documentation is developed in accordance with the laws of the countries where the service operates and with FATF (Financial Action Task Force) recommendations.

The main objectives of the Policy:

- Eliminating the possibility of using the site for illegal activities.

- Full compliance with regulatory requirements.

- Maintaining the impeccable reputation of the 24PayBanks brand.

- Increased level of trust from customers and regulators.

This document is part of the User Agreement. By using the service, the client confirms their full agreement with the terms of the Policy. 24PayBanks reserves the right to update this document unilaterally by publishing the changes on the official website.

2. Data security and privacy

The 24PayBanks platform"s priority is protecting users" personal information.

3. Know Your Customer (KYC) and Sanctions Policy

To verify an account, the user must provide scans or photos of documents (transliteration into Latin is required).

Identity verification (optional):

1. International or domestic passport.
2. ID card (identity card).
3. driver"s license.

Proof of residential address (document issued up to 3 months ago):

- Lease agreement or bank statement.

- Utility bills.

- Income declaration (tax).

- Other official documents indicating the registration address.

Additional requirement:

A selfie of a user holding a piece of paper with the current date, personal signature, and the name "24PayBanks" written on it.

Sanction restrictions

The service prohibits servicing residents of countries and territories under UN, EU, OFAC, or FATF sanctions, as well as individuals under 18 years of age.

Prohibited jurisdictions: Afghanistan, Iran, North Korea, Syria, Yemen, Libya, Somalia, Cuba, Crimea, Transnistria, Venezuela, Myanmar (Burma), as well as other regions included in the sanctions lists at the time of the operation.

Verification terms

- Standard check: 1–24 hours.

- Extended Date Discovery (EDD): 24-72 hours.

- Note: If suspicions arise, the service may request a repeat KYC check.

4. Risk management and operations monitoring (KYT)

Transaction analysis is carried out using automated systems from leading AML monitoring providers.

Risk factors:

- Linking addresses to fraudulent schemes, darknet markets, or sanctions lists.

- Use of anonymization tools (mixers, including Tornado Cash).

- Suspicious behavior patterns (smurfing, operations from disadvantaged regions).

Risk Score

Important: Threshold values may vary depending on the software. A detailed Risk-Score model is described here: https://www.bestchange.ru/wiki/detailed_aml_recommendations.pdf#page=72.

Transactions marked "High Risk" are blocked automatically. Users can check the status in advance using the tool: https://www.bestchange.com/report.

Client categorization

1. Low Risk: Standard Check (CDD).
2. Medium risk: Enhanced monitoring, re-verification every 2 years.
3. High Risk: Enhanced Due Diligence (EDD). Includes analysis of the origin of funds, transaction history, and annual KYC updates. Applies to politically exposed persons (PEPs) and residents of countries on the FATF High-Risk list.

If you refuse verification:

- Freezing of funds for a period of 7-10 business days.

- Upon expiration of the period, the materials may be transferred to the competent authorities (law enforcement agencies, financial intelligence).

5. Actions in case of suspicious activity and refunds

When signs of illegal activity are detected, the 24PayBanks administration follows the following algorithm:

1. Immediate suspension of the operation.
2. Account blocked pending investigation.
3. Preparation of internal report (SAR/STR).
4. Notification to regulators if necessary (EU FIU, FinCEN, Rosfinmonitoring).

Refund Policy:

- For bona fide users, only network fees are charged.

- In AML cases, the return commission is up to 5%, but not more than $100.

- Refunds are not possible if funds are deemed criminal or subject to confiscation at the request of regulators.

6. Internal control and work with partners

Requirements for counterparties:

- A ban on cooperation with platforms from jurisdictions with weak AML regulations.

- Mandatory due diligence procedure for partners.

- Partners have licenses and comply with international standards.

Audit and training:

- AML Officer: [email protected].

- Annual professional development of personnel in the field of AML/CTF.

- Internal audits are conducted quarterly (it is possible to involve external experts).

7. Payment standards

All payments are made in accordance with the standards of international regulators (FATF, OFAC) through:

1. Licensed platforms.
2. Unique one-time crypto addresses.
3. Low-risk addresses (confirmed by AML analyzers).

Questions for the AML officer: [email protected]