PalWallet


Last updated: January 2026


1. Introduction
PalWallet is committed to maintaining the highest standards of compliance with international Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) regulations.
This policy outlines the principles, controls, and procedures implemented to prevent the use of PalWallet’s platform for money laundering, terrorist financing, fraud, and other financial crimes.
PalWallet operates in accordance with applicable laws and regulatory requirements in all jurisdictions where its services are provided.

2. Regulatory Framework
PalWallet’s AML and KYC framework is aligned with international standards and regulations, including but not limited to:
• Financial Action Task Force (FATF) Recommendations
• EU Anti-Money Laundering Directives (AMLD)
• Markets in Crypto-Assets Regulation (MiCA)
• Local financial crime and AML legislation in supported jurisdictions
• Sanctions and watchlists issued by OFAC, EU, UN, and other authorities

3. Scope of Policy
This policy applies to:
• All PalWallet users
• All PalWallet products and services
• All employees, contractors, and partners
• All fiat and crypto transactions conducted on the platform

4. Customer Due Diligence (KYC)
PalWallet applies a risk-based approach to customer verification.

4.1 Identity Verification
All users must complete identity verification before accessing regulated services. This includes:
• Full legal name
• Date of birth
• Nationality
• Residential address
• Government-issued photo ID
• Liveness and biometric verification
• Proof of address where required
Business users must provide:
• Company registration documents
• Beneficial ownership details
• Director and shareholder information
• Business activity description

4.2 Risk Assessment
Each customer is assessed based on:
• Country of residence
• Transaction behaviour
• Source of funds
• Politically Exposed Person (PEP) status
• Sanctions exposure
• Business activity risk
Higher-risk customers may be subject to Enhanced Due Diligence (EDD).

5. Enhanced Due Diligence (EDD)
EDD is applied to high-risk users including:
• Politically Exposed Persons
• High-volume traders
• Users from high-risk jurisdictions
• Complex ownership structures
EDD measures may include:
• Source of funds verification
• Source of wealth verification
• Additional documentation
• Ongoing monitoring

6. Transaction Monitoring
PalWallet operates continuous transaction monitoring using automated and manual controls.
Monitoring includes:
• Unusual transaction patterns
• Rapid movement of funds
• Structuring or layering behaviour
• High-risk wallet interactions
• Sanctioned wallet screening
• Blockchain analytics and tracing
Suspicious activity is flagged, reviewed, and escalated where necessary.

7. Sanctions and Watchlist Screening
All users and transactions are screened against global sanctions lists, including:
• OFAC
• EU Sanctions
• UN Sanctions
• UK HMT
• Interpol and law enforcement databases
Users linked to sanctioned entities are blocked immediately.

8. Suspicious Activity Reporting
PalWallet maintains internal procedures for identifying and reporting suspicious activity.
Where required by law, PalWallet files Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) with relevant authorities.
PalWallet cooperates fully with regulators and law enforcement agencies.

9. Record Keeping
PalWallet retains customer and transaction records in accordance with regulatory requirements, typically for a minimum of five years.
Records include:
• KYC documentation
• Transaction history
• Risk assessments
• Compliance reviews
• Audit logs

10. Data Protection and Privacy
All personal data is processed in accordance with applicable data protection laws including GDPR.
User data is:
• Encrypted
• Stored securely
• Access-controlled
Used only for regulatory and operational purposes

11. Staff Training and Compliance Oversight
All PalWallet staff receive regular AML and KYC training.
A designated Compliance Officer is responsible for:
• Oversight of AML and KYC programmes
• Regulatory reporting
• Policy enforcement
• Internal audits
• Regulatory liaison

12. Ongoing Monitoring and Review
This policy is reviewed regularly to ensure continued compliance with:
• Regulatory changes
• Industry best practices
• Emerging financial crime risks
• Technological developments

13. Zero Tolerance Policy
PalWallet maintains a zero-tolerance approach to financial crime.
Any attempt to misuse the platform for illegal activity will result in:
• Account suspension or termination
• Asset freezing where legally required
• Reporting to authorities


14. Contact
For compliance-related inquiries, please contact:
Compliance Team PalWallet

Email: [email protected]