AML / Compliance Policy
Anti-Money Laundering & Counter-Terrorist Financing Policy · Last updated: June 1, 2025
Our Commitment
SR Global Markets CryptoGateway is committed to preventing money laundering, terrorist financing, and other financial crimes. We implement robust controls to detect, prevent, and report suspicious activity in compliance with applicable AML/CFT regulations.
1. Prohibited Uses
The CryptoGateway platform must not be used to process payments connected to:
- Money laundering or structuring transactions to avoid reporting thresholds
- Financing of terrorism or sanctioned entities
- Proceeds of criminal activity including drug trafficking and fraud
- Transactions involving OFAC, EU, or UN sanctioned individuals or jurisdictions
- Darknet marketplace activity
- Ransomware payments or extortion proceeds
- Unregistered securities or unlicensed financial services
2. Merchant Due Diligence
We apply a risk-based approach to merchant onboarding. Merchants may be required to provide:
- Business registration documents
- Identity verification for controlling persons
- Description of business activities and expected transaction volumes
- Source of funds documentation for high-value transactions
- Proof of address and operating licences where applicable
3. Transaction Monitoring
We continuously monitor transactions for:
- Unusual transaction volumes or patterns inconsistent with declared business
- High-frequency small transactions that may indicate structuring
- Payments involving wallet addresses flagged on blockchain analytics databases
- Rapid in-and-out movement of funds
- Payments from or to high-risk jurisdictions
4. Record Keeping
In accordance with financial regulations, we retain:
- All transaction records for a minimum of 7 years
- Merchant KYC/identity documents for 7 years after account closure
- Suspicious activity reports and related correspondence
- API access logs and IP address records for 90 days
5. Reporting Suspicious Activity
We file Suspicious Activity Reports (SARs) with relevant financial intelligence units where required by law. Merchants who become aware of suspicious activity related to payments processed through our platform should report it immediately.
6. Account Termination
SR Global Markets reserves the right to immediately suspend or terminate any merchant account where we reasonably suspect involvement in money laundering, terrorist financing, or other prohibited activities. We may freeze pending settlements pending investigation and are under no obligation to disclose the reason for account suspension to the affected party.