Compliance Program
Program Elements
Customer Identification Program (CIP)
Ace Payment Services, Inc. maintains a Customer Identification Program requiring collection and verification of identity attributes for all account applicants, in accordance with applicable federal requirements for money services businesses.
Know Your Customer (KYC) Review
The KYC process collects required personal and business information from applicants. Information is evaluated against risk criteria to determine eligibility for account access.
AML Monitoring
Anti-Money Laundering controls are applied on an ongoing basis to account activity. The program is designed to detect and prevent illicit financial activity in accordance with the Bank Secrecy Act and applicable FinCEN guidance.
OFAC Screening
All applicants and account holders are screened against the Office of Foreign Assets Control (OFAC) sanctions lists and other applicable government watchlists. Accounts associated with sanctioned parties are not permitted.
Transaction Monitoring
Account transactions are subject to ongoing monitoring for unusual patterns, policy violations, and compliance concerns. Monitoring controls are applied based on account type, transaction type, asset type, and network.
Risk Scoring
Customer and transaction risk scoring is applied as part of the compliance program. Risk scores inform onboarding decisions, transaction review thresholds, and account-level controls. Risk scoring does not eliminate all compliance risks.
Enhanced Due Diligence
Customers or transactions presenting elevated risk indicators are subject to Enhanced Due Diligence, which may include additional identity verification, source-of-funds review, or account restrictions.
Suspicious Activity Review
Transactions or account behaviors that raise compliance concerns are subject to internal escalation and review. The company complies with applicable suspicious activity reporting requirements.
Recordkeeping
Transaction and identity records are maintained in accordance with applicable law, including Bank Secrecy Act recordkeeping requirements. Records are retained for the legally required period.
Jurisdiction Restrictions
Wallet account services are not available in all jurisdictions. Eligibility is determined based on applicable state and federal law, licensing status, and product availability. Services are subject to change based on regulatory developments.
Prohibited Activity Monitoring
Accounts and transactions are reviewed for prohibited activities including fraud, money laundering, terrorist financing, sanctions evasion, ransomware-related activity, and unauthorized use. Accounts involved in prohibited activities are subject to suspension or termination.
Prohibited Activities
- Fraud
- Money laundering
- Terrorist financing
- Sanctions evasion
- Unauthorized third-party transfers
- Stolen funds
- Ransomware-related activity
- Illegal goods or services
- Market manipulation
- Use of mixers or obfuscation tools where prohibited
- Transactions involving restricted jurisdictions
- Attempts to bypass identity or account controls
Compliance controls do not eliminate all financial, fraud, sanctions, cybersecurity or blockchain risks.