1. Introduction
1.1. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy defines the procedures implemented by OCTOPRO OÜ (operating as PROSTO.CARDS) to prevent money laundering, terrorist financing, and other financial crimes.
1.2. The Policy is developed in compliance with:
- EU Anti-Money Laundering Directives (AMLD);
- the Money Laundering and Terrorist Financing Prevention Act of Estonia;
- applicable international standards (FATF Recommendations).
1.3. All employees, partners, and contractors of the Service are required to comply with this Policy.
2. Know Your Customer (KYC) Procedures
2.1. Basic Verification
All Users must provide:
- full name;
- date of birth;
- country of residence.
2.2. Enhanced Verification
Required for fiat (RUB) deposits and upon Service request. Includes:
- government-issued identity document (passport, national ID);
- selfie / liveness check;
- proof of address (utility bill, bank statement — not older than 3 months);
- source of funds declaration.
2.3. Ongoing Monitoring
The Service continuously monitors User activity and may request updated documents at any time.
3. Risk Assessment
3.1. The Service applies a risk-based approach to all Users:
- Low risk: standard verification, standard limits;
- Medium risk: enhanced verification, reduced limits;
- High risk: enhanced due diligence, possible refusal of service.
3.2. Risk factors include but are not limited to:
- country of residence or nationality (high-risk jurisdictions);
- transaction patterns and volumes;
- source of funds;
- politically exposed person (PEP) status;
- sanctions list screening.
4. Transaction Monitoring
4.1. The Service implements automated transaction monitoring systems that analyze:
- transaction amounts and frequency;
- geographic patterns;
- merchant category codes (MCC);
- unusual or suspicious behavior;
- structuring patterns.
4.2. Transactions may be automatically flagged, delayed, or blocked pending review.
4.3. The Service reserves the right to decline any transaction without explanation.
5. Suspicious Activity
5.1. Indicators of suspicious activity include:
- unusually large or frequent transactions;
- transactions with no apparent economic purpose;
- attempts to structure transactions to avoid reporting thresholds;
- use of multiple accounts;
- inconsistent information provided by the User;
- transactions involving high-risk jurisdictions;
- reluctance to provide requested information.
5.2. Upon detection of suspicious activity, the Service will:
- freeze the account and associated funds;
- conduct an internal investigation;
- file reports with relevant authorities if required.
6. Sanctions Screening
6.1. The Service screens all Users and transactions against:
- EU sanctions lists;
- UN sanctions lists;
- OFAC (US) sanctions lists;
- other applicable sanctions regimes.
6.2. The Service will refuse to onboard or immediately terminate any User identified on a sanctions list.
6.3. Transactions involving sanctioned countries, entities, or individuals are strictly prohibited.
7. Prohibited Activities
7.1. The following activities are strictly prohibited through the Service:
- money laundering in any form;
- terrorist financing;
- tax evasion;
- fraud and scam operations;
- transactions related to illegal goods or services;
- circumvention of sanctions;
- cash-out and encashment schemes;
- gambling and betting (unless explicitly permitted);
- payment arbitrage and abuse.
8. Record Keeping
8.1. The Service maintains records of:
- all User identification data and documents;
- all transactions conducted through the Service;
- internal investigation results;
- suspicious activity reports.
8.2. Records are retained for a minimum of 5 years after termination of the business relationship, or longer if required by applicable law.
9. Reporting Obligations
9.1. The Service will file Suspicious Activity Reports (SARs) with the Estonian Financial Intelligence Unit (Rahapesu Andmebüroo) when required.
9.2. The Service is prohibited from informing the User that a report has been or will be filed (tipping-off prohibition).
9.3. The Service cooperates fully with law enforcement and regulatory authorities.
10. Cryptocurrency-Specific Measures
10.1. Given that the Service accepts USDT (TRC-20) deposits:
- blockchain analytics tools may be used to trace fund origins;
- deposits from mixing services, darknet markets, or flagged addresses will be rejected or frozen;
- USDT deposits are one-way only — no cryptocurrency withdrawals are available.
10.2. The Service may request proof of cryptocurrency source at any time.
11. Refusal of Service and Termination
11.1. The Service reserves the right to:
- refuse to establish a business relationship;
- refuse to execute a transaction;
- terminate an existing relationship;
if the User:
- fails to provide required identification information;
- provides false or misleading information;
- is suspected of involvement in money laundering or terrorist financing;
- is listed on sanctions lists;
- otherwise poses an unacceptable risk.
11.2. Funds may be retained or forfeited in case of confirmed violations.
12. Policy Updates
12.1. This Policy is reviewed and updated regularly to ensure compliance with evolving legal requirements and best practices.
12.2. The current version is always available on the website.
12.3. Continued use of the Service constitutes acceptance of the updated Policy.
13. Contact
For AML/KYC inquiries:
OCTOPRO OÜ
Harju maakond, Tallinn, Roseni tn 13
Email: [email protected]