GiftPay AML Policy

GiftPay, Inc. (individually, the “Company”), incorporated under the laws of the State of Delaware offers services for merchants to accept gift cards as payment for their products / services.

The Company is registered as a Money Services Business with the United States Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”). GiftPay's Anti-Money Laundering (“AML”) policies and procedures are designed to deter illicit activities on the platform, protect the users, the business, and the digital currencies and financial services communities from exploitation by criminals. The Company is compliant with the requirements, regulations and guidance imposed by FinCEN.

https://www.fincen.gov/sites/default/files/shared/20111102.pdf

https://www.fincen.gov/sites/default/files/news_release/20110726b.pdf

As part of GiftPay’s Compliance policies, Know Your Customer (“KYC”) policies and procedures for individual and institutional customers have been designed to enable the Company to form a reasonable belief that it knows the true identity of those of its customers for which such review has been performed. The policy applies to all users on the platform and is followed by all of the Company’s employees, consultants, officers, owners and directors.

Using a risk based approach as part of KYC & AML Compliance, GiftPay has taken the following measures:

  • Establishing and maintaining risk-based KYC.
  • Cooperation with law enforcement requests and local regulatory requirements;
  • Filing of Suspicious Activity Reports (“SARs”);
  • Company-wide BSA/AML/OFAC training;
  • Use of various anti-fraud systems;
  • Ongoing rule based transaction monitoring;
  • Investigations using blockchain analytics;
  • Blocking all TOR traffic.

We file SARs if we know, suspect or have reason to suspect suspicious activities have occurred on our platform. A suspicious transaction is often one that is inconsistent with a user’s known and legitimate business, personal activities or personal means.

The Company has also adopted ongoing OFAC sanctions policies and procedures designed to protect the platform from being used for prohibited transactions, by sanctioned individuals or for the purposes of evading, avoiding or otherwise circumventing U.S. and global sanctions.

GiftPay fully cooperates with all OFAC, Specially Designated Nationals (SDN) and Blocked persons sanctions lists. Please refer to the following LIST for the Company's list of risk-based banned countries that are prevented from using GiftPay's platform.

Where GiftPay has provided you with a translation of the English language version of this policy, then you agree that the translation is provided for your convenience only and that the English language versions of the policy will govern your relationship with GiftPay. If there is any contradiction between what the English language version of the policy says and what a translation says, then the English language version shall control.