DRAFT for legal review. Not legal advice. Not yet in force.
AML and acceptable use policy
Last updated: DRAFT, 12 October 2026
How Payster works to keep the service away from money laundering, terrorist financing, sanctions breaches and fraud. Template draft: the final program must be designed with a compliance officer for the confirmed jurisdiction.
1. Roles
Payments are processed by independent licensed providers. Those providers carry out customer identity verification (KYC), sanctions screening and transaction monitoring under their own licences. Payster supports that work and applies its own controls on merchant access.
2. Our controls
- Merchant acceptance review against the Prohibited activities list.
- Screening of payout wallet addresses against public sanctions lists and known illicit-activity addresses. [Vendor to be selected.]
- Monitoring for unusual patterns such as rapid volume spikes, repeated failed payments or complaint clusters.
- Suspension of access when risk indicators are found, and cooperation with providers and authorities.
- Record keeping of merchant and transaction data for the legally required period.
3. Merchant obligations
- Sell only lawful goods and services and describe them accurately.
- Do not split, disguise or route payments for other businesses.
- Do not accept payments from, or pay out to, sanctioned persons or jurisdictions.
- Respond to reasonable information requests from us or from a provider.
4. Restricted jurisdictions
Each provider publishes its own list of unsupported countries. [Counsel to add the platform-level restricted jurisdiction list.]
5. Reporting concerns
Report suspected misuse to [email protected]. We do not tip off subjects of a report.