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Legal

AML/KYC Policy

Last updated: October 23, 2026

1. Purpose

This Policy explains the merchant's AML, licensing, and sanctions responsibilities, how Paymos checks the addresses of incoming payments and withdrawals, when Paymos may request identity information, and how restrictions imposed by an upstream settlement provider affect a Paymos balance.

2. No Verification at Sign-Up

Onboarding is documentless — you can register and start testing without submitting identity documents. However, we reserve the right to require identity verification (KYC/KYB) at any later point, including when:

  • —Activity is flagged as suspicious.
  • —Transaction or withdrawal limits are exceeded.
  • —A regulatory or law-enforcement authority requests it.
  • —A manual review or competent authority requires additional information.

Verification may require a government-issued identity document, proof of address, and related records. If verification is requested and not completed, we may suspend account operations.

3. Transaction Monitoring

Paymos checks blockchain addresses for AML risk on money moving in both directions: the address that sends an invoice payment or a payment-channel deposit, and the recipient address of every merchant withdrawal. The check runs automatically in Production; nothing is checked in Sandbox. Its sources are TRM Labs, Binance AML, AMLBot, PureFi, and the screening provider's own database of flagged addresses.

An incoming payment is checked as soon as the transfer appears on the network. When the sender's address passes, the invoice is marked paid, or the channel deposit confirmed, at the same moment it would be without the check, and that result holds for 24 hours for the same address on the same network. When the address fails, or the result is inconclusive, the payment is held: the invoice is not marked paid, the channel deposit is not confirmed, and you are notified in the dashboard, by email and in Telegram. Your customer's payment page says only that the payment has arrived and is being processed. A held payment does not keep the invoice open, so the invoice expires at its deadline. Funds released later are credited under the usual rules. Release is not guaranteed, and there is no manual release.

If the check itself is technically unavailable, an incoming payment can go through without a result, after the usual network confirmations and under the usual payment rules. That never applies to a payment whose address has failed the check. Withdrawals wait in that situation until a result is in.

Before a withdrawal is sent, Paymos checks its recipient address again, every time, without reusing an earlier result. The withdrawal waits for that result. If the address fails, nothing is sent: the withdrawal fails, the amount reserved for it returns to your balance, and you are notified. In a withdrawal to several recipients, only the payment to that address stops. A new withdrawal to a different address can be created as usual.

The check looks at addresses, not at people, and it is not an identity check of you or your customers. Merchants are responsible for the transaction-monitoring and sanctions controls required by their business, licences, and jurisdictions. The screening does not transfer that responsibility to Paymos, and passing it does not mean the funds are free of risk or that the underlying activity is lawful.

4. Sanctions

Sanctions compliance is the merchant's responsibility, and the address check in Clause 3 does not change that. An upstream settlement provider may also restrict or freeze funds under its own sanctions policy; if it does, Paymos applies the same restriction to the affected merchant balance.

5. Merchant Responsibility

The legality, licensing, and AML compliance of your business is your obligation and your risk. Paymos does not vet your business, check licences, screen your category, or approve or refuse who you may serve. You are responsible for understanding and meeting every law that applies to you and your customers.

Using the Service does not transfer that responsibility to Paymos, and does not mean your activity is lawful.

6. Suspicious Activity

Where we identify suspicious activity, we may:

  • —Request additional identity or source-of-funds verification.
  • —Suspend account operations.
  • —Freeze funds pending investigation.
  • —Report the activity to competent authorities.

7. Consequences of Violation

If your use of the Service breaches this Policy or applicable law, we may block your account, freeze your funds, and disclose information to the relevant authorities — without prior notice where the law requires or permits it. Frozen funds may be withheld pending the outcome of an investigation.

8. Record-Keeping

Verification data and transaction records are retained for at least five years from the end of the business relationship, in line with applicable record-keeping requirements.

AML/KYC questions: [email protected]