AdFiCard Legal

AML / KYC / KYB Policy

Last updated: 2026 · Contact: support@adficard.com

1. Purpose and Scope

AdFiCard applies a risk-based anti-money laundering, counter-terrorist financing, sanctions, and customer due diligence framework designed to protect the platform, our partners, and the broader financial ecosystem.

This Policy applies to onboarding, account maintenance, funding activity, balance usage, card activity, refund activity, suspicious behavior review, and related compliance controls across the Services.

2. Customer Due Diligence

— We may require identity verification for individuals, including government-issued identification, liveness checks, proof of address, and other supporting information.

— We may require business verification for companies, including incorporation records, ownership and control information, business activity details, beneficial owner identification, authorized representative verification, and any other supporting information we reasonably request.

— We may request source-of-funds, source-of-wealth, commercial rationale, merchant activity, advertising activity, expected volume, or additional supporting documents before or after onboarding. Failure or refusal to provide requested information may result in delay, restriction, suspension, or termination.

3. Risk-Based Review

— We apply a risk-based approach. Different users, jurisdictions, wallet profiles, transaction patterns, industries, and use cases may be subject to different review levels.

— Enhanced due diligence may be required for higher-risk customers, unusual activity, politically exposed persons, sanctioned exposure, high-volume usage, complex ownership structures, or other elevated risk indicators. Our internal thresholds, scoring methods, detection logic, and review criteria are confidential and may be changed from time to time without notice.

— Verification is not a one-time event. We may refresh diligence, request updated documents, or re-screen information at any time.

4. Transaction Monitoring and KYT

— We may use blockchain analytics, sanctions screening, wallet risk tools, transaction monitoring tools, behavioral review, and manual investigation to assess deposits, refunds, and related activity.

— We may review wallet addresses, transaction hashes, counterparties, geographic exposure, transaction patterns, source indicators, adverse media, and other risk signals. We are not required to disclose internal methodologies, alerts, thresholds, or the existence of internal reports except where disclosure is required by law.

— Transactions may be delayed, rejected, reversed where possible, or placed on hold while we complete compliance review.

5. Prohibited Activity

— The Services may not be used for money laundering, terrorist financing, sanctions evasion, fraud, deceptive conduct, payment layering, nominee activity, or any unlawful purpose.

— We prohibit the use of funds linked to theft, scams, ransomware, darknet activity, mixers or tumblers, sanctioned parties, prohibited jurisdictions, or other high-risk or unlawful sources.

— We also prohibit false information, forged documents, use on behalf of undisclosed third parties, or attempts to bypass our controls or our partners' controls.

6. Actions We May Take

— We may request additional information or documents, reject onboarding, delay funding availability, freeze or restrict balances, decline transactions, suspend cards, suspend accounts, terminate the relationship, or take any other protective action we reasonably consider necessary.

— We may refuse or delay a refund request if compliance review is incomplete, if suspicious activity is identified, if partner or legal restrictions apply, or if unresolved obligations remain.

— Where appropriate or required, we may file internal reports, cooperate with partners, or disclose information to competent authorities. We may be unable to explain certain actions or reviews where doing so would be unlawful, inappropriate, or inconsistent with the integrity of our controls.

7. Sanctions and Restricted Access

We do not provide Services to persons, entities, or activities prohibited by applicable sanctions laws, embargoes, or internal restrictions. Access may also be restricted in jurisdictions or sectors that we or our partners determine are not supportable from a compliance or risk perspective.

8. Recordkeeping

We may retain verification records, transaction records, sanctions screening results, review notes, and related compliance materials for as long as reasonably necessary to satisfy legal, regulatory, contractual, audit, fraud prevention, partner, or dispute requirements.

9. Policy Updates and Contact

We may amend this Policy from time to time to reflect legal, operational, or risk changes. Questions regarding this Policy may be directed to support@adficard.com.