Anti-Money Laundering and Know Your Customer Policy
This is a public summary of the anti-money-laundering and counter-terrorist-financing programme operated by ATLAS PAY LIMITED. The full internal programme, including thresholds, screening parameters and escalation procedures, is confidential: publishing it would tell the people it is designed to stop how to avoid it.
1. Our position
ATLAS PAY LIMITED is a company incorporated in Hong Kong, Business Registration Number 79950367.
We do not currently hold a licence for virtual asset services in any jurisdiction, and we make the service available only where it may lawfully be provided without one. We nevertheless apply the customer due diligence and record-keeping standards set out below, modelled on the Financial Action Task Force Recommendations and on the standards applied under Hong Kong's Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). Section 3 states plainly which checks we do not perform today.
We do not accept anonymous accounts, accounts opened under a false name, or accounts operated on behalf of an undisclosed third party.
2. Customer due diligence
Before a user may deposit, withdraw, transfer or obtain a card, we verify their identity. This requires:
- an official identity document, checked for authenticity and validity;
- a live selfie check, confirming that a living person is present and that the face matches the document;
- name, date of birth and country of residence; and
- a verified email address and mobile telephone number.
Verification is carried out with the assistance of a specialist identity verification provider acting on our instructions. We remain responsible for the outcome.
We may ask for further information at any time, including the source of funds and the purpose of a transaction, and we may restrict an account until we receive a satisfactory answer.
3. Screening
We would rather tell you exactly what we check than imply more than we do.
What verification does. It establishes that the identity document is genuine and valid, that the person presenting it is physically present, and that their face matches the document. It also establishes name, date of birth and country of residence, and it verifies an email address and a telephone number.
What we do not do today. We do not operate automated screening of users against sanctions lists, against lists of politically exposed persons, or against adverse media. We do not operate automated screening of blockchain addresses against databases of darknet markets, ransomware proceeds, mixing services or stolen funds. We do not claim otherwise.
What we do instead. We restrict the countries from which an account can be opened, we act on information brought to us by a provider, a counterparty, a user or an authority, and we act on what our own review finds under section 5. These controls are under active review, and we will update this Policy when they change — in either direction.
4. Who we will not serve
We rely for this on the country restrictions we apply, on the identity document you provide, on what you tell us, and on information that reaches us. Read it with section 3: this is a rule we enforce when we learn of a breach, not a claim that we detect every breach automatically.
We do not open or maintain accounts for:
- anyone subject to sanctions, or resident in a sanctioned territory;
- anyone under 18;
- anyone who refuses or fails identity verification, or who provides a document that is not genuine;
- anyone acting for an undisclosed third party; or
- anyone we reasonably believe intends to use the service for an unlawful purpose.
We do not serve businesses. Accounts are for personal use only.
5. Ongoing monitoring
We review activity where something brings it to our attention: an alert from a provider, a report from a user or a counterparty, a request from an authority, or a pattern noticed by our team — structuring, rapid pass-through of funds, activity inconsistent with a stated source of funds, or a link to a flagged address. We do not represent that every transaction is reviewed automatically.
Where a concern arises, we may hold a transaction, ask for further information, freeze a balance, block a card or close an account. Where the law permits we explain what we have done. In some cases we are legally prohibited from telling a user that a report has been made, and we will not do so.
6. Reporting
Where we know or suspect that funds are the proceeds of crime or are connected to terrorist financing, we report to the competent authority in the relevant jurisdiction, including the Joint Financial Intelligence Unit in Hong Kong. A report is made without notifying the user, as the law requires.
7. Records
We keep customer due diligence records and transaction records for at least six years after the business relationship ends, in line with the period applied under Hong Kong's Anti-Money Laundering and Counter-Terrorist Financing Ordinance. Six years is a minimum, not an expiry date: our financial ledger is append-only, so these records are de-identified rather than erased when they are no longer needed to identify a customer. How that works, and what it means for you, is set out in section 9 of our Privacy Policy at https://alt.vu/legal/privacy/.
8. Governance and training
A named senior officer is responsible for this programme and for the decision to make a report. Staff with access to customer accounts receive anti-money-laundering training before they are given that access and at least annually afterwards. The programme is reviewed at least once a year and whenever the service, the countries we serve or the applicable rules change materially.
9. Cooperation with authorities
We respond to lawful requests from law enforcement, regulators and courts. We require an order or request that is valid in the jurisdiction concerned, and we disclose only what it covers.
10. Contact
Questions about this Policy: legal@alt.vu Law enforcement and regulatory requests: legal@alt.vu, marked for the attention of the Compliance Officer.
ATLAS PAY LIMITED Unit 1603, 16/F, The L. Plaza, 367–375 Queen's Road Central, Sheung Wan, Hong Kong