Legal
AML, KYC and Sanctions Policy
How Ravelo verifies the merchants it serves, screens deposits and addresses, and holds funds that need review. It tells you what to expect and what we ask of you.
Last updated
01Purpose and scope
We want crypto payments to reach honest businesses and not to help anyone launder money, finance crime or evade sanctions. This policy covers merchants, their team members and owners, and the payments, balances and payouts on their accounts. It sits alongside the Terms of Service and the Acceptable Use Policy.
The compliance contact is [Compliance contact email]. The person responsible for this policy is [Name or title of the compliance officer].
02Verifying merchants (KYB and KYC)
Before live payments or payouts are switched on, we check who the merchant is. We usually ask for:
- the business's legal name, address, registration details, website and what it sells;
- the people who own or control it, and those who will act for it, with identity documents;
- how the business expects to use the service: volumes, assets, countries and customers;
- a source of funds or business explanation where the risk calls for it.
Staff cannot mark a merchant as verified alone: the decision is approved by a second person. We review again when something changes, such as new owners, new business lines, unusual activity or a request for higher limits, and we may ask for fresh documents. Until a review is done, an account may have lower limits or be paused.
Payers who pay through a merchant's checkout are not asked to open an account. They may still be subject to screening of the address and transaction they use.
03Sanctions and risk screening
We screen merchants, owners and representatives against sanctions lists. We also screen the wallet addresses and transactions on inbound and outbound payments using blockchain-analytics tools, including those of our payment provider 2328 and [Screening and blockchain-analytics provider]. We look at, for example, links to sanctioned persons, mixers, stolen funds, scams and other illicit sources.
We apply rules for which countries may open accounts and receive payouts. These rules are versioned, kept in configuration, and enforced in every channel before an instruction is executed.
04Holds and reviews
A deposit that raises a screening flag is held. It is not credited to the merchant's balance and cannot be spent or paid out through any route until a reviewer decides. The merchant's payment shows a compliance-hold state, and the merchant should not fulfil the order.
| Outcome | What happens |
|---|---|
| Released | The flag is cleared, the payment is credited as normal. A release is approved by a second person. |
| Returned | The funds are sent back to the origin where that is lawful and possible, less network costs. |
| Retained or reported | Where the law requires it, funds stay frozen and we report to the competent authority. We may be forbidden to tell you. |
We may ask the merchant or payer for information to resolve a hold. How long it takes depends on the case; we do not promise a fixed time. Holds can also come from our provider.
Tipping off
05Ongoing monitoring
We monitor activity against what a merchant told us to expect, and for patterns such as structuring payments below limits, rapid in-and-out movement, use of many addresses without a reason, and sudden changes in volume or countries. Payout destinations are saved in advance, wait out a delay before use, and need a fresh passkey confirmation. We may add checks, lower limits, pause a merchant or end the relationship.
06Transfer information
Where a rule requires information on the sender and recipient to travel with a transfer, we collect it and pass it on through the means the rule allows. We may ask merchants for it.
07Records
We keep verification documents, screening results, decisions and an audit trail of who did what, for the period in the Privacy Policy. Staff actions on sensitive matters are recorded and need approval from a second person.
08What we ask of merchants
- Tell us the truth and keep your information up to date; tell us about changes in ownership or business.
- Do not accept payments for prohibited goods or services, or for someone else's business, without our written agreement.
- Do not try to split, disguise or route funds to avoid a check or a hold.
- Answer our questions promptly and in full, including requests about a particular payment.
- Tell us if you suspect a payment is linked to crime.
09If we cannot complete a check
If we cannot verify a merchant, or a review cannot be finished, we may decline or close the account, hold funds, refuse payouts or return funds to their origin, and we may report the matter as the law requires.
10Contact
Questions about this policy, a hold or a request for information: [Compliance contact email]. Complaints follow the Complaints Procedure.