Legal Framework
VolkPay Inc. is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. This policy sets out the controls and procedures we maintain to prevent the platform from being used for financial crime.
VolkPay operates in accordance with applicable AML legislation, including the Financial Action Task Force (FATF) Recommendations, applicable EU Anti-Money Laundering Directives, the USA PATRIOT Act, and the Bank Secrecy Act (BSA). We work exclusively with licensed financial institution partners subject to equivalent regulatory obligations.
VolkPay maintains a designated Money Laundering Reporting Officer (MLRO) responsible for overseeing our AML/CTF programme and managing all regulatory reporting obligations.
Know Your Customer (KYC)
All users are required to complete identity verification before accessing card issuance or fund transfer functionality. Our KYC programme includes:
Identity Verification
Government-issued photo identification (passport, national ID, or driving licence) combined with biometric liveness detection to prevent spoofing.
Address Verification
Proof of residential address required for users assessed as higher-risk, including Politically Exposed Persons (PEPs) and users from elevated-risk jurisdictions.
Source of Funds
Declaration and, where required, documentation of the origin of deposited assets, including blockchain address ownership verification.
Ongoing Monitoring
Continuous review of account activity against established risk profiles, with periodic re-verification for long-standing accounts.
Risk-Based Approach
We apply a risk-based approach to customer due diligence (CDD). Users classified as higher-risk are subject to Enhanced Due Diligence (EDD), which may include:
- Additional documentary evidence of identity and address.
- Source of wealth declarations and supporting documentation.
- Senior management approval for account onboarding.
- Increased transaction monitoring thresholds and alert sensitivity.
- Periodic account reviews at shorter intervals than standard profiles.
Transaction Monitoring
VolkPay employs automated transaction monitoring systems to detect unusual or suspicious activity in real time. Alert indicators include:
- Transactions inconsistent with a customer's stated purpose or established profile.
- Rapid movement of funds with no clear economic rationale.
- Deposits or withdrawals involving blockchain addresses flagged by chain analytics tools.
- Transactions structured to avoid reporting thresholds.
- Any connection to jurisdictions or counterparties subject to international sanctions.
Suspicious Activity Reporting
Where we identify suspicious activity, we are legally required to file a Suspicious Activity Report (SAR) with the relevant financial intelligence unit. We are prohibited by law from disclosing to the subject of a SAR that a report has been made ("tipping off" prohibition).
Accounts under SAR review may be restricted without prior notice. This is a legal requirement and does not necessarily indicate wrongdoing.
Sanctions Compliance
VolkPay screens all users and transactions against applicable sanctions lists in real time:
- UN Security Council Consolidated Sanctions List.
- OFAC Specially Designated Nationals (SDN) List.
- EU Consolidated Financial Sanctions List.
- HMRC/HM Treasury Consolidated Sanctions List.
- Other relevant national and supranational sanctions regimes.
Accounts and transactions associated with sanctioned parties will be blocked immediately and reported to the relevant authorities without notice.
Record Keeping
We retain KYC records, transaction data, SAR documentation, and all compliance records for a minimum of five (5) years following the termination of a customer relationship, in accordance with applicable financial crime legislation.
Staff Training
All VolkPay personnel with compliance responsibilities undergo mandatory AML/CTF training on joining and at regular intervals thereafter. Training covers:
- Recognising indicators of money laundering and terrorist financing.
- Internal escalation and SAR filing procedures.
- Obligations under applicable sanctions regimes.
- Consequences of non-compliance for the firm and for individuals.
Contact
To report compliance concerns, or for AML-related enquiries, contact our Compliance team at compliance@volkpay.cc. Reports may be made confidentially.