KYC & AML Policy
KYC & AML Policy
This Due Diligence and Anti-Money Laundering (AML) Policy describes the measures adopted by EZ PIN (“EZ PIN,” “we,” “us,” or “our”) to conduct customer and business due diligence, prevent money laundering, terrorist financing, fraud, sanctions violations, and other illegal or unauthorized activities in connection with our products, APIs, platforms, and services.
1) Regulatory Commitment
EZ PIN is committed to complying with all applicable AML, counter‑terrorism financing (CTF), sanctions, and financial crime prevention laws and regulations, including those applicable in the United States and the United Arab Emirates. We maintain a risk‑based compliance framework appropriate for prepaid, stored‑value, and digital code distribution.
2) Scope of This Policy
This Policy applies to:
- All commercial customers, resellers, distributors, merchants, partners, directors, employees, and affiliates
- API users, POS customers, and platform account holders
- All prepaid, stored‑value, digital code, and related services provided by EZ PIN
3) Customer Due Diligence (KYC/KYB)
EZ PIN applies a risk‑based approach to customer due diligence. Depending on the nature, geography, and risk profile of the customer, EZ PIN may collect and verify information including but not limited to:
- Legal business name, registration number, and address
- Ownership and control information (including beneficial owners)
- Authorized signatories and key management personnel
- Government‑issued identification and supporting verification documents
- Business activity description and intended use of EZ PIN services
4) Ongoing Monitoring
EZ PIN conducts ongoing monitoring of customer activity to identify unusual, suspicious, or potentially illegal behavior. Monitoring may include:
- Transaction pattern and volume analysis
- Unusual sales timing, spikes, or geographic anomalies
- Monitoring of API usage, POS activity, and order behavior
- Review of complaints, chargebacks, and fraud indicators
5) Sanctions Compliance
EZ PIN complies with applicable sanctions laws and regulations, including those administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). EZ PIN does not permit its products or services to be used by:
- Individuals or entities subject to applicable sanctions or watchlists
- Persons located in, or ordinarily resident in, sanctioned or restricted countries
- Transactions that would result in a violation of sanctions laws or regulations
6) Prohibited Activities
Customers and partners must not use EZ PIN Services for fraudulent, illegal, unauthorized, or high-risk activities, including but not limited to:
- Money laundering or terrorist financing
- Sanctions evasion or circumvention
- Unauthorized resale, sub‑distribution, or misuse of digital codes
- Use of EZ PIN Services in violation of applicable laws, sanctions requirements, provider terms, or EZ PIN policies
7) Right to Suspend or Terminate
EZ PIN reserves the right, at its sole discretion, to suspend, restrict, or terminate access to its services immediately if it reasonably believes that:
- Suspicious, fraudulent, or illegal activity has occurred or may occur
- Information provided during registration or KYC is false, misleading, or incomplete
- Continued service would violate applicable laws, regulations, or provider requirements
8) Cooperation with Authorities
EZ PIN may cooperate with regulators, law enforcement, and competent authorities where required or permitted by applicable law, including by providing information, records, or transaction data in response to valid lawful requests.
9) Data Protection
Information collected for Due Diligence and AML purposes is handled in accordance with EZ PIN’s Privacy Policy and applicable data protection laws. Access to such information is restricted to authorized personnel only.
The data collected will be retained for record-keeping, dispute management purposes for the period necessary to comply with applicable laws and regulations.
10) Policy Updates
This Policy may be updated from time to time to reflect changes in laws, regulations, or risk management practices. Updated versions will be published on our website.
11) Contact
For questions regarding this Due Diligence and AML Policy or compliance matters, please contact [email protected].