AML / KYC Policy

Last updated: July 2, 2026

Furlpay operates a risk-based anti-money-laundering (AML) and counter-terrorist-financing (CTF) program. Identity verification, sanctions screening and transaction monitoring are built into the product, not bolted on.

1. Customer Due Diligence (KYC)

Before accessing regulated features, customers complete identity verification through our KYC partner Persona — government ID capture, selfie match and liveness (PAD) checks. Verification is tiered: higher limits and features require higher assurance.

• Tier 0 — email / phone only, minimal functionality.
• Tier 1–2 — ID + liveness, standard limits.
• Tier 3 — enhanced due diligence for higher limits and business accounts.

2. Sanctions & PEP screening

Customers and, where applicable, counterparties are screened against sanctions lists (e.g. OFAC, EU, UN) and politically-exposed-person (PEP) and adverse-media data. Wallet addresses are screened for AML risk before high-value transfers via our chain-analytics seam.

3. Transaction monitoring

• Real-time device and behavioural risk scoring gates transfers.
• Rules flag structuring, velocity anomalies and high-risk counterparties.
• Step-up verification is required for high-value or sensitive actions.

4. FATF Travel Rule

For qualifying VASP-to-VASP transfers above the reporting threshold, required originator and beneficiary information is exchanged in line with the FATF Travel Rule. See the compliance docs.

5. Suspicious activity & record-keeping

Suspicious activity is escalated to the relevant authorities where required, and records are retained in line with applicable law. Accounts may be frozen or closed where legally required or where risk thresholds are exceeded.