Contents
1. Our Commitment
SmartHolder ("we", "us", "our") is committed to preventing the use of its Service for money laundering ("ML"), terrorist financing ("TF"), sanctions evasion, and other financial crime. This Anti-Money Laundering ("AML") Policy describes the principles and controls we apply to detect and deter such activity, consistent with applicable laws and good industry practice.
2. Scope
This Policy applies to all users of the Service and to all interactions involving card issuance, wallet connection, and on-chain approvals. It works alongside our Terms of Use and Privacy Policy.
3. Definitions
- Money Laundering — the process of disguising the origin of proceeds of crime so they appear legitimate.
- Terrorist Financing — providing or collecting funds to be used for terrorist acts.
- Sanctions — restrictive measures imposed by governments and international bodies against persons, entities, or jurisdictions.
- Beneficial Owner — the natural person who ultimately owns or controls a wallet or transaction.
4. Risk-Based Approach
We apply a risk-based approach proportionate to the nature of the Service. This means allocating resources and controls according to the level of ML/TF risk presented by particular activities, wallets, networks, or transaction patterns, and enhancing scrutiny where higher risk is identified.
5. Sanctions & Restricted Persons
The Service may not be used by, or on behalf of, any individual or entity that is:
- listed on any applicable sanctions or watch list;
- located in, or a resident of, a comprehensively sanctioned or prohibited jurisdiction;
- acting to evade sanctions or other legal restrictions.
We may screen wallet addresses and related data against sanctions and risk databases and may decline or restrict access where a match or elevated risk is identified.
6. Prohibited Activities
You must not use the Service in connection with funds derived from or intended for:
- fraud, theft, ransomware, or other criminal proceeds;
- darknet marketplaces or illegal goods and services;
- terrorist financing or proliferation financing;
- mixing/tumbling services used to obscure the origin of funds for illicit purposes.
7. Transaction Monitoring
We may monitor on-chain activity associated with the Service for indicators of suspicious or high-risk behavior, including unusual patterns, links to flagged addresses, and structuring. Where appropriate, we may use third-party blockchain-analytics tools to support this monitoring.
8. No-KYC & Reserved Rights
While the standard card-issuance flow does not require identity verification (KYC), we reserve the right, at our sole discretion or where required by law, to:
- request additional information or documentation;
- delay, restrict, suspend, or decline a transaction or account;
- conduct enhanced due diligence on higher-risk interactions.
9. Suspicious Activity Reporting
Where we identify activity that we reasonably suspect involves ML, TF, or other financial crime, we may file reports with the relevant authorities and cooperate with lawful investigations, in accordance with applicable law. We may be prohibited by law from disclosing that a report has been made ("tipping off").
10. Record Keeping
We retain relevant records — including transaction data, communications, and any information gathered through due diligence — for the period required by applicable law, and make them available to competent authorities upon lawful request.
11. Training & Governance
We maintain internal procedures designed to keep personnel aware of AML/CTF obligations and red flags relevant to their roles. Responsibility for this Policy and for handling escalations sits with our designated compliance function.
12. Updates
We review and update this Policy periodically to reflect regulatory developments and changes to the Service. The "Last updated" date above indicates the most recent revision.
13. Contact
To report a concern or contact our compliance function, email [email protected] or reach general support at [email protected].