By using the Services of XPay Software Limited, Users agree to comply with this AML Policy and all related requirements. “Users” refers to any individuals or legal entities who access, register for, or make use of the products, services, platforms, or technology solutions provided or operated by the Company, whether directly or through integrated third-party applications.
This includes prospective customers undergoing onboarding, active customers transacting on the Platform, and any party initiating or receiving transactions, submitting information, using wallets or cards, or otherwise interacting with the Company’s infrastructure.
This AML Policy forms a binding agreement between the Company and the User. All Users are required to comply with the terms of this AML Policy at all times. Any instance of non-compliance may result in the termination of such User’s accounts on the XPay Platform and, where applicable, reporting of the circumstances of such non-compliance to relevant statutory authorities.
Integrity, honesty, and ethical business practices are core values of the Company. XPay Software Limited strongly condemns any activities related to terrorism, money laundering, sanctions evasion, fraud, or any other unlawful actions.
To prevent misuse of the Services provided through the XPay Platform, Users are required to strictly comply with the terms of this AML Policy, which forms an integral part of the User Agreement. Users must read, understand, and agree to the terms set out herein before using the Services. Any User who does not agree with these terms must not register or continue to use the Platform.
This AML Policy supersedes and replaces any prior oral or written understandings or agreements between XPay Software Limited and the User with respect to anti-money laundering and counter-terrorist financing compliance.
“Company” or “XPay Software Limited” – XPay Software Limited, as registration number 238654, a company duly organized and existing under the laws of Seychelles, and having a registered office address at 306 Victoria House, Victoria, Mahé, Seychelles. The Company operates the Platform, provides the Services, and is responsible for implementing this AML Policy.
“User” or “Customer” – any individual or legal entity that accesses, registers for, or uses the Services, Products, Platform, Applications, or interfaces developed, operated, or provided by the Company. This includes persons interacting with the Telegram Mini App (MA), the Progressive Web Application (PWA), integrated third-party environments, or any functionality enabling transactions, wallet operations, or card-related services.
“Services” – all services, products, and functionalities made available by the Company through the MA, PWA, Platform, APIs, or any other digital or non-digital environment. Services include, but are not limited to: digital asset processing, wallet operations, card issuance integrations, transaction execution, account management, and any related technical or customer-facing features.
“Platform” – the ecosystem of applications, systems, interfaces, APIs, MA, PWA, databases, and technical infrastructure operated or provided by the Company for the purpose of delivering the Services.
“Applications” or “Apps” – the Telegram Mini App (“MA”), the Progressive Web Application (“PWA”), and any other interfaces developed by the Company that enable Users to access the Platform and Services.
“Customer Due Diligence (CDD)” – measures taken to identify and verify the User, assess the purpose and nature of the business relationship, and evaluate the User’s risk profile.
“Enhanced Due Diligence (EDD)” – additional verification and monitoring measures applied to high-risk Users, transactions, or scenarios.
“Verification Levels / KYC Tiers” – structured levels of identity verification determining the User’s access to Services based on assessed risk.
“Risk-Based Approach (RBA)” – allocating AML/CFT measures proportionately to the level of risk associated with a User, product, transaction, or jurisdiction.
“Ongoing Monitoring” – continuous review of User activity, behaviour, transactions, technical signals, and risk indicators to ensure consistency with the User’s risk profile.
“Transaction Monitoring” – analysis of User transactions to detect unusual patterns, inconsistencies, or suspicious activity.
“Blockchain Monitoring” – assessment of blockchain activity, wallet addresses, counterparty flows, and exposure to high-risk or illicit categories.
“Sanctions Screening” – checking Users, transactions, and blockchain addresses against internationally recognised sanctions regimes and any partner-required lists.