KYC/AML/CFT Compliance Policy

At ZixiPay LLC (“ZixiPay”, “we”, “us”), we are committed to preventing and mitigating the risks associated with illegal activities, including money laundering, terrorist financing, and other illicit conduct. In alignment with EU directives and the Financial Action Task Force (FATF) recommendations, we have established comprehensive internal procedures and mechanisms to uphold the integrity of our services.

Summary of our internal AML policy:


1. Know Your Customer (KYC)

We enforce a stringent KYC verification process to authenticate the identities of our clients and relevant individuals within their corporate structures. The creation of anonymous accounts is strictly prohibited. Clients must complete a detailed questionnaire and undergo mandatory video verification to ensure compliance.


2. Transaction Monitoring (KYT)

ZixiPay conducts thorough verifications, assessing client reputation, geographical location, and applicable licenses. Clients are permitted to designate a single bank account for all transactions, with deposits and withdrawals exclusively processed through this account. We implement real-time monitoring of virtual currency transactions. Should we detect suspicious activities—such as crypto deposits from unverified sources or actions indicative of fraud—we reserve the right to:

  1. Initiate an internal investigation
  2. Suspend or close the client's account
  3. Nullify any pending payments
  4. Temporarily halt service provision

All suspicious transactions are promptly reported to the relevant authorities.


3. Anti-Money Laundering (AML) and Sanctions Screening

We employ rigorous safeguards to prevent involvement in money laundering and terrorist financing. This includes comprehensive screening of all clients, including controllers and beneficial owners, with a dedicated focus on sanctions screening. We are committed to maintaining up-to-date information on clients' beneficial ownership and conduct periodic reviews to ensure ongoing compliance.


4. Service Availability

ZixiPay does not offer services to individuals located in jurisdictions identified by the EU and FATF as high-risk or non-cooperative due to significant AML/CFT deficiencies. Additionally, we do not extend our services to citizens and residents of the United States.


5. Risk Assessment

We adopt a comprehensive Risk-Based Approach across our operations. This involves the systematic identification, assessment, understanding, and mitigation of AML/CFT risks, considering factors such as customer profiles, product characteristics, geographic considerations, and distribution channels.