AML & KYC Policy

Effective 2026-08-04

1. Risk-based approach

MiniGateway operates a tiered, risk-based compliance program. Every invoice address and payout destination is scored automatically; high-risk subjects and merchants are escalated for manual review.

2. Tiered verification (KYC)

Tier 0 merchants operate frictionlessly with a verified email and aggregate risk below the high-risk threshold. Merchants that trigger a compliance event (high risk score or daily volume above the configured limit) must complete minimal KYC — identity and wallet-ownership proof — before held settlements and payouts are released.

3. Sanctions & watchlists

Screenings include deterministic blocklist checks for known-bad subjects in addition to statistical heuristics. Accounts or transactions linked to sanctioned entities or individuals are blocked.

4. Reporting

We cooperate with competent authorities and will file suspicious-activity reports where legally required. We may freeze or reject transactions pending investigation.

5. Record keeping

AML screening results and KYC submissions are retained for the period required by applicable regulation and are accessible to authorized compliance personnel only.

6. Review & decisions

Approvals and rejections are made by authorized staff who record notes. A rejected merchant may correct and re-submit its verification.

This document is provided for informational purposes and does not constitute legal advice. Consult a qualified professional for advice tailored to your jurisdiction.