EasyLoade.com – Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy

Registered Address: 27 Rue de Geroldseck, 67200 Strasbourg, France
Compliance Contact: [email protected]

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Table of Contents

• 1. Purpose & Scope
• 2. Regulatory Framework
• 3. Key Definitions
• 4. Customer Acceptance Policy
• 5. Identity Verification (CIP)
• 6. Enhanced Due Diligence (EDD)
• 7. Risk-Based User Classification
• 8. Transaction Monitoring
• 9. Suspicious Activity Identification
• 10. Sanctions & Watchlist Screening
• 11. Ongoing Monitoring & Review
• 12. Account Freezing & Restrictions
• 13. Reporting to Authorities
• 14. Record Keeping & Retention
• 15. Compliance Oversight
• 16. User Responsibilities
• 17. Policy Amendments

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1. Purpose & Scope

This AML/CTF Policy outlines EasyLoade.com's commitment to preventing the use of its platform for money laundering, terrorist financing, fraud, and other financial crimes. It applies to all customers, merchants, wallet holders, payment channels, currency flows, and transactions processed within the EasyLoad ecosystem.

2. Regulatory Framework

EasyLoade.com aligns its AML controls with:

• European Union AML Directives (AMLD5 / AMLD6)
• FATF (Financial Action Task Force) Recommendations
• Know-Your-Customer (KYC) & Customer Due Diligence (CDD) Principles
• International Sanctions Lists (UN, EU, OFAC)

3. Key Definitions

• Money Laundering: Concealing or disguising the origin of illegally obtained funds.
• Terrorist Financing: Providing or collecting funds to support terrorism.
• Beneficial Owner: Individual who owns or controls ≥25% of an entity.
• PEP: Politically Exposed Person.
• Suspicious Transaction: Any activity lacking clear legal or economic purpose.

4. Customer Acceptance Policy

We prohibit accounts belonging to:

• Individuals or entities on sanctions lists
• Anonymous or unverifiable customers
• Users from prohibited or high-risk jurisdictions without enhanced verification
• Users associated with fraud, terrorism, or illegal trade

5. Identity Verification (Customer Identification Program – CIP)

Every user must complete identity verification including:

• Valid government-issued identification
• Selfie or biometric verification
• Verified mobile number and email
• Device and IP fingerprinting
• Proof of address where required

6. Enhanced Due Diligence (EDD)

EDD is conducted for higher-risk users such as:

• Politically Exposed Persons (PEPs)
• Users exceeding financial usage thresholds
• Crypto, cross-border, or large-value transactions
• Users with irregular or high-risk behavioral patterns

AML Verification Thresholds

To comply with financial crime prevention standards, EasyLoade.com applies tiered identity and document verification requirements based on cumulative transaction volume within a rolling 12-month period.

Total Usage	Verification Required	Purpose
Up to €500	Basic identity verification (ID + selfie)	Customer onboarding
Above €500	Government-issued ID + Selfie verification	Enhanced user identification
Above €2,000	Proof of Address (utility bill or official statement)	Address verification & risk reduction
Above €5,000	Proof of Income (salary slip, contract, or bank statement)	Source-of-funds validation

Failure to provide the requested documentation may result in temporary restrictions or suspension of account activity until verification is completed.

7. Risk-Based User Classification

Customers are categorized into risk levels (Low, Medium, High) based on:

• Country of origin
• Identity documentation quality
• Transaction volume & frequency
• Wallet activity & currency flow
• Device and IP intelligence

8. Transaction Monitoring

EasyLoade.com continuously monitors transactions to identify:

• Large or rapid transfers
• Structuring or layering patterns
• Unusual QR payment behavior
• Repeated deposits and withdrawals
• Transactions inconsistent with user risk profile

9. Suspicious Activity Identification

Transactions may be flagged when they involve:

• Unjustified source of funds
• Transfers to unrelated or unknown beneficiaries
• High-risk geographic routing
• Attempts to bypass KYC thresholds
• Abnormal account access or device behavior

10. Sanctions & Watchlist Screening

All customers and payment beneficiaries are screened against global sanctions databases. Any confirmed match results in immediate suspension and compliance escalation.

11. Ongoing Monitoring & Review

EasyLoade.com conducts periodic reviews of customer accounts, identity records, and transaction patterns to ensure continued compliance.

12. Account Freezing & Restrictions

We reserve the right to temporarily or permanently freeze accounts and wallet balances when suspicious or sanction-related activity is detected. Frozen funds remain secured pending investigation or instruction from competent authorities.

13. Reporting to Authorities

EasyLoade.com may submit Suspicious Transaction Reports (STR) to Financial Intelligence Units and cooperate fully with law enforcement and regulatory agencies.

Crypto & Digital Asset Compliance

EasyLoade.com supports certain digital asset payment flows. To prevent misuse of cryptocurrency for money laundering or illicit financing, we apply the following controls:

• All crypto deposits and withdrawals are risk-screened using blockchain analytics tools.
• Wallet addresses associated with sanctions, dark-web markets, mixers, or illegal services are automatically blocked.
• Large or suspicious crypto transactions trigger Enhanced Due Diligence (EDD).
• We reserve the right to freeze crypto-related balances pending compliance investigation.
• Users must demonstrate the legitimate origin of crypto funds when requested.

EasyLoade.com does not allow the use of anonymizing crypto services, privacy coins, or suspicious blockchain routing intended to conceal transaction sources.

14. Record Keeping & Retention

• Customer identification records: 10 years after closure
• Transaction logs: 10 years
• Suspicious activity records: 12 years

15. Compliance Oversight

EasyLoade.com maintains internal AML risk engines, audit trails, compliance workflows, and ongoing system improvements to uphold financial crime prevention standards.

16. User Responsibilities

• Provide truthful and complete identification information
• Keep personal and financial details updated
• Do not use the platform for unlawful activities
• Report suspicious or fraudulent transactions

17. Policy Amendments

This AML/CTF Policy may be revised periodically. Any updates will apply on a forward-looking basis and be communicated through our official channels.

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Report Suspicious Activity: [email protected]