1. Purpose and scope
TokenPe is registered with the Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury as a Money Services Business, Registration No. [FINCEN MSB NUMBER]. FinCEN registration is not a licence and does not mean that FinCEN endorses TokenPe. This public summary describes the anti-money laundering (AML), counter-terrorist financing and sanctions programme that applies to all TokenPe services, merchants and transactions.
2. Our BSA/AML programme
TokenPe maintains a written, risk-based AML programme under the Bank Secrecy Act (BSA) and its implementing regulations. The programme includes:
- a designated BSA/AML Compliance Officer, responsible for day-to-day compliance and reporting to senior management;
- written policies, procedures and internal controls, approved by senior management;
- regular training for staff, appropriate to their roles;
- independent testing of the programme, carried out by qualified people who are independent of the compliance function;
- a risk assessment of our products, customers, geographies and delivery channels, reviewed at least once a year.
3. Know your business (KYB) and know your customer (KYC)
We verify every merchant before it can use our services. We collect and verify:
- the legal name, registration number, registered address and place of business;
- company formation documents and proof of good standing;
- the identity of directors, authorised signatories and every individual who owns 25% or more of the business or controls it;
- the nature of the business, its websites, products, target markets and expected volumes;
- the licences or registrations the business needs, including gaming licences;
- source of funds and, where required, source of wealth.
We verify individuals using government-issued identification and independent data sources. We screen merchants, their owners and controllers against sanctions lists, politically exposed person lists and adverse media before onboarding and on an ongoing basis.
4. Risk rating and enhanced due diligence
Every merchant receives a risk rating at onboarding, which we review periodically and when risk changes. We apply enhanced due diligence (EDD) to higher-risk merchants. EDD can include more documents, source of wealth checks, website and product reviews, management interviews, senior management approval, lower limits, and more frequent reviews.
Gaming and casino operators are always treated as higher risk and always receive EDD, which includes:
- verifying each gaming licence directly with the issuing authority and recording its scope and expiry date;
- confirming the markets the operator serves and the controls it uses to block players from markets where it is not licensed;
- reviewing the operator's own AML, player KYC, age verification, responsible gaming and geolocation controls;
- reviewing the operator's terms, websites and marketing;
- confirming that US players are served only where the operator holds a licence from the state where the player is located;
- monitoring licence status and repeating the review at least once a year.
See also the Gaming Operator Requirements.
5. Sanctions compliance
TokenPe complies with the sanctions programmes administered by the US Treasury's Office of Foreign Assets Control (OFAC) and other sanctions laws that apply to us.
- We screen merchants, owners, controllers, payout recipients and wallet addresses against the OFAC Specially Designated Nationals and Blocked Persons List and other relevant lists.
- We block or reject transactions involving sanctioned persons, sanctioned wallet addresses or prohibited jurisdictions, and report them to OFAC as required.
- We use IP address and other controls to prevent access from prohibited jurisdictions.
6. Prohibited jurisdictions
We do not onboard merchants, process transactions or make payouts involving the following jurisdictions:
- Jurisdictions subject to comprehensive US sanctions: Cuba, Iran, North Korea, and the Crimea, so-called Donetsk People's Republic and so-called Luhansk People's Republic regions of Ukraine.
- As a matter of TokenPe policy, jurisdictions that the Financial Action Task Force (FATF) has identified as high-risk jurisdictions subject to a call for action.
We may restrict further jurisdictions based on our risk assessment, partner requirements or changes in law. We keep the current list up to date on this page and in the merchant dashboard, and apply other list-based OFAC programmes to persons and transactions wherever they are located.
7. Blockchain analytics and transaction monitoring
- We screen incoming and outgoing transfers and wallet addresses with blockchain analytics tools, to identify exposure to sanctioned addresses, darknet markets, mixers, scams, stolen funds and other illicit activity.
- We monitor transactions for unusual patterns, including activity that does not match the merchant's profile, structuring, and rapid movement of funds.
- High-risk alerts are reviewed by our compliance team. We may hold, reject or return funds, ask for information, or close an account.
- Funds that may be subject to sanctions or legal orders are dealt with as the law requires.
8. Travel Rule and recordkeeping
We collect, keep and transmit originator and beneficiary information for transfers as required by the BSA recordkeeping and Travel Rule requirements, including for transmittals of $3,000 or more.
9. Reporting
- We file Suspicious Activity Reports (SARs) with FinCEN as required by law, including for suspicious transactions of $2,000 or more that are conducted by, at or through TokenPe.
- We file Currency Transaction Reports (CTRs) where required.
- SARs are confidential. We do not tell anyone that a SAR has been filed or considered, as the law prohibits it.
- We respond to lawful requests from law enforcement and regulators, including FinCEN information requests.
10. Record keeping
We keep KYB/KYC records, transaction records, screening results and reports for at least five years, as required by the BSA, and longer where required by law.
11. Merchant responsibilities
Merchants must:
- give us complete and accurate information and keep it up to date;
- respond to our information requests promptly, normally within five business days;
- run their own AML and KYC controls where their licences or laws require it;
- not use our services to evade sanctions, launder money, finance terrorism or carry out any other illegal activity;
- tell us promptly about any regulatory action, licence change or investigation that affects them.
12. Consequences
If a merchant breaches this policy or presents unacceptable risk, we may request information, hold funds, limit services, reject transactions, close the account and report to the authorities.