1.Purpose of the policy
This policy describes the measures Sim7 Technologies OÜ takes to prevent the platform from being used to launder proceeds of crime, finance terrorism, or circumvent sanctions.
This document is public and discloses our approach to the extent that doing so does not reduce the effectiveness of the measures themselves. Internal thresholds, scoring rules, and indicator lists are not published.
The policy is mandatory for all employees, and certain of its provisions are mandatory for platform users by virtue of the accepted public offer.
2.Principles and scope
We build our controls on a risk-based approach: the depth of checks is proportional to the risk of a specific user and transaction, not applied uniformly to everyone.
This policy applies to topping up and spending the internal balance, partner-program payouts, and refunds to external details.
The Service is not a credit institution and does not transfer funds between users: the internal balance is spent exclusively on paying for platform services. This alone significantly limits the potential for abuse.
3.Risk assessment
Each account is assigned a risk level, which is reassessed as the nature of its transactions changes.
The assessment is influenced by the following factors:
- the user's jurisdiction and the jurisdiction of the payment instrument;
- the amounts and frequency of top-ups relative to actual spending on orders;
- the share of refunds to external details relative to funds spent;
- signs of coordinated behavior across multiple accounts;
- results of screening against sanctions and other restrictive lists.
4.Customer identification
The basic use case for the platform does not require submitting documents: an email address is enough to register.
Enhanced verification is requested when certain events occur — exceeding cumulative top-up thresholds, requesting a refund to details other than those used for payment, or triggering suspicious-transaction indicators.
As part of such verification, we may request an identity document, proof of address, information on the source of funds, and, for legal entities, registration documents and information on beneficial owners.
Related transactions are suspended until the verification is complete. Refusal to provide the requested information is grounds for refusing the transaction and terminating the agreement.
5.Transaction monitoring
All payment events and orders undergo automatic screening at the moment they occur. Monitoring rules compare an account's behavior against its usual profile and against typical abuse patterns.
A rule triggering does not imply the user is at fault: most signals are resolved automatically or after a brief clarifying question from a compliance officer.
The results of checks are recorded in an internal log, along with the decision taken and its rationale.
6.Signs of suspicious transactions
Indicators that require additional attention include, among others:
- topping up the balance by a significant amount followed immediately by a refund request without using the service;
- splitting top-ups into many small payments from different instruments;
- using payment instruments registered to third parties without a reasonable explanation;
- mass creation of accounts sharing common technical fingerprints;
- ordering numbers in a pattern typical of registering financial products in someone else's name;
- attempts to use the service from jurisdictions subject to restrictive measures.
7.Payment methods and cryptocurrency
We accept payment only through licensed payment providers and do not deal in cash.
For cryptocurrency payments, incoming addresses are screened for links to addresses known to be associated with illicit activity. Funds received from higher-risk addresses are not credited to the balance until the review is complete.
Refunds are made via the same method and to the same details from which the payment was received. A refund to different details is only possible after enhanced verification.
8.Sanctions screening
Accounts and payment counterparties are checked against current sanctions lists of the European Union, the UN, and other applicable regimes. Screening is performed at registration and re-run whenever the lists are updated.
Platform access is not granted to individuals included in such lists, or to those acting on their behalf. Discovering a match after registration results in immediate suspension of service.
9.Service suspension and freezing of funds
Upon reasonable suspicion, transactions on an account are suspended for the time needed to verify, but for no more than thirty calendar days, unless otherwise required by law or by a competent authority.
The user is notified of the suspension to an extent that does not hinder the review. We are not obligated to disclose which specific indicators triggered it, as that would reduce the effectiveness of our controls.
If the suspicion is not confirmed, access is fully restored and the suspended transactions proceed with no additional conditions. If a violation is confirmed, the agreement is terminated, and funds found to have been obtained unlawfully are not returned pending a decision by the competent authority.
10.Record retention
Information obtained during identification, verification results, and transaction records are kept for at least five years from the end of the relationship with the user.
Access to such information is limited to compliance staff. Data storage and protection follow the privacy policy.
11.Responsible officer and training
The company has designated an officer responsible for enforcing this policy. They report directly to management and have the authority to suspend transactions without further approval.
Employees involved in customer service and payment processing are trained upon hiring and at least once a year. The policy is reviewed annually, and off-schedule whenever the law changes materially.
12.Interaction with authorities
For transactions where suspicion remains after our internal review, we inform the competent authority in the manner and within the timeframes established by law.
Requests from competent authorities are fulfilled provided they are properly formalized. Send questions about this policy to compliance@sim7.org.