EnterPay takes its obligations to prevent financial crime seriously. This AML & KYC Policy (hereinafter: the "Policy") sets out our approach to Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), Know-Your-Customer (KYC), and Know-Your-Business (KYB) compliance.
Please review this Policy carefully, as they set forth legally binding terms and conditions between you and EnterPay that govern your access and/or use of the Service (as defined below); the Terminal (as defined below); the Platform (as defined below), whether such access and/or use is via the Website (as defined below), the Platform (as defined below), locally installed programs and/or (other) software and/or hardware devices.
By accessing and/or using the Service (as defined below), you agree to this Policy on behalf of yourself and any entity you represent and you represent and warrant that you are not a Prohibited Person (as defined below) and/or that you are not residing in a Excluded Jurisdiction (as defined below) and that you have the right and authority to do so. This Policy is available for download and print at https://enterpay.com/aml.
1.1 In this Policy, the following terms, always capitalised and used in both singular and plural, shall have the following meanings:
1.1.1 Account: means the user profile, which can be created via the Website, which allows the User to access and use the Service, and which forms part of the Service;
1.1.2 Agreement: means the agreement between the Parties for the access to and/or use of the Service, to which this Policy apply, and of which the Policy forms an integral part;
1.1.3 Applicable Law: means all national, supranational, state, and local laws, statutes, regulations, rules, directives, ordinances, codes, recommendations, official guidance, and orders issued by any competent judicial, Governmental, or regulatory authority having jurisdiction over EnterPay and/or the User and/or the Customer, its operations, or the relevant activity. This includes, without limitation, all applicable laws and regulations relating to Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), including the Financial Action Task Force (FATF) Recommendations, economic or financial sanctions, and Anti-Bribery and Corruption (ABC), and including the Travel Rule (MiCA/TFR), each as amended, supplemented, or replaced from time to time;
1.1.4 Customer: means the User's client;
1.1.5 Didit: means Didit Identity Spain S.L., an ISO 27001-certified, GDPR-compliant identity verification platform, didit.me;
1.1.6 Documentation: means the documentation as accessible at the Website;
1.1.7 EnterPay: means EnterPayment OÜ, the company established under the laws of the Republic of Estonia, registered with the Estonian Chamber of Commerce under registration number 17391111;
1.1.8 Excluded Jurisdiction: means Iran, North Korea, Syria, the People's Republic of China and/or a jurisdiction identified by the Financial Action Task Force (FATF) for strategic AML/CFT deficiencies and included in FATF's listing of "High-risk and Other Monitored Jurisdictions" accessible at fatf-gafi.org and/or a jurisdiction in which the Service would be subject of licensing and/or in which crypto asset payments are prohibited;
1.1.9 Features: means the Services' current features, which can be updated by EnterPay at any time, as described in the Documentation and/or on the Website;
1.1.10 GDPR: means Regulation (EU) 2016/679 ('General Data Protection Regulation');
1.1.11 Governmental: means any nation or government, any state or other political subdivision thereof, any entity that exercises legislative, executive, judicial or administrative functions of or pertaining to government, including but not limited to any governmental agency, regulator, agency, department, council, committee or agency and any court, tribunal or arbitrator(s) with competent jurisdiction and any self-regulatory organisation, as well as private entities exercising quasi-governmental, regulatory or judicial functions anywhere in the world;
1.1.12 Parties: means you/the User and EnterPay;
1.1.13 Platform: means the application which EnterPay makes available to the User indirectly through the Website, and through the Terminal, as described on the Website and in the Documentation, and which forms part of the Service;
1.1.14 Privacy Statement: means EnterPay's privacy statement, as available on https://enterpay.com/privacy;
1.1.15 Prohibited Person: means any citizen, resident of, or person established or residing in any region, including Excluded Jurisdictions, where the use of the Service is prohibited, or any entity, including, but not limited to, any company or partnership incorporated or organised in or under the laws of any region, including Excluded Jurisdictions, where the use of the Service is prohibited;
1.1.16 Service: means the provision of the Website and (Features of) the Platform and/or Terminal, as described on the Website and in the Documentation;
1.1.17 Terminal: means the hardware or software interface provided to the User for accepting crypto asset payments, and which forms part of the Service;
1.1.18 User: means the Party that concluded the Agreement with EnterPay for the use of the Service and/or uses (parts of) the Service without concluding the Agreement;
1.1.19 Website: means the website accessible at https://enterpay.com, including all associated subdomains, web pages, and all content, data, files, and resources made available through them (such as text, images, scripts, and other materials), which together form part of the Service.
2.1 This Policy shall apply to the Agreement, on creating and managing the Account and to the Service. Any conditions of the User, such as general conditions, do not apply and are expressly rejected.
2.2 The User will be prompted to accept this Policy before creating an Account and using the Platform.
2.3 EnterPay will not provide Services to Users engaged in:
2.3.1 Gambling, betting, or online gaming operators that do not hold a valid licence in each jurisdiction in which they operate;
2.3.2 Weapons, firearms, or ammunition dealing;
2.3.3 Adult entertainment services involving sexually explicit content or services (licensed hospitality and nightlife venues are not captured by this exclusion);
2.3.4 Narcotics or controlled substances;
2.3.5 Counterfeit goods;
2.3.6 Shell companies with no identifiable ultimate beneficial owner (UBO);
2.3.7 Any entity subject to international sanctions;
2.3.8 Pyramid schemes or unlicensed investment solicitation;
2.3.9 Any activity illegal in the jurisdiction of operation.
2.4 These Terms have been prepared in English. In these Terms:
2.4.1 reference to any statute includes a reference to that statute as amended, extended or re-enacted and to any regulation, order, instrument or subordinate legislation under the relevant statute;
2.4.2 reference to the singular includes a reference to the plural and vice versa;
2.4.3 reference to "or" is not exclusive and "include" and "including" shall not be construed or read to be limiting;
2.4.4 reference to a law or regulation includes any amendment or modification to such law or regulation and any further rules issued thereunder or any law or regulation in replacement therefor;
2.4.5 references to a natural person or legal entity includes its successors or assigns, to the extent permitted under these Terms;
2.4.6 any rights of either Party may be exercised at any time and from time to time unless specified otherwise in these Terms;
2.4.7 reference to "written/in writing" in these Terms also refers to email communication, provided the identity of the sender and the integrity of the contents is adequately established;
2.4.8 reference to an article or paragraph in these Terms shall be a reference to such an article or paragraph of the body of these Terms, and not to any attachment or other document, unless where explicitly provided otherwise;
2.4.9 specific references in (the body of) these Terms to other parts of these Terms shall be without prejudice to the full general applicability of any unreferenced provision or part thereof;
2.4.10 the headings of articles or paragraphs of these Terms are for ease of reference only and shall not affect the interpretation of the respective rights and obligations of the Parties and shall not form any part of these Terms for the purposes of construction; and
2.4.11 the wording of these Terms shall be decisive in interpreting the mutual rights and obligations of the Parties under these Terms.
3.1 EnterPay is a technology platform. EnterPay does not hold, custody, exchange, or transmit funds or crypto assets on its own account.
3.2 EnterPay's regulated financial partners are primarily responsible for Customer KYC, transaction monitoring, and suspicious activity reporting. EnterPay is primarily responsible for User onboarding (KYB) and operates an additional, risk-based identity verification layer at the Terminal through its integration with Didit.
3.3 EnterPay holds no VASP, CASP, EMI, payment-institution, or other regulatory licence in its own name. All regulated activity is performed by licensed, regulated partners under their own authorisations. Didit provides identity-verification technology only and is not a licensed compliance entity.
3.4 Onboarding decisions are made on the basis of verification results, and EnterPay does not guarantee approval of any application and is not liable for delays arising from incomplete or pending verification. Any registration or licence referenced is held by the relevant licensed partner, not by EnterPay.
3.5 Before any User is permitted to use the Platform, EnterPay conducts KYB due diligence on the User. EnterPay verifies the User's:
3.5.1 Certificate of incorporation;
3.5.2 Business registration details;
3.5.3 Trading name;
3.5.4 Identity of all natural persons who ultimately own or control 25% or more (UBOs);
3.5.5 Government-issued identity documents for all directors;
3.5.6 Current proof of business address;
3.5.7 Description of the merchant's business, customer base, and sector.
3.6 All Users and their beneficial owners (UBOs) are screened against international sanctions lists, PEP databases, and adverse media databases.
3.7 EnterPay provides merchants with the ability to activate identity verification at the Terminal, powered by Didit. KYC may be triggered based on transaction value, customer jurisdiction, or merchant configuration.
3.8 EnterPay is committed to full compliance with all applicable international sanctions regimes including OFAC, EU Consolidated List, UN Consolidated List, UK HM Treasury, and UAE sanctions. Any potential sanctions match is immediately escalated to our MLRO for review.
4.1 All EnterPay personnel with AML/KYC responsibilities complete AML awareness training on joining and annually thereafter.
4.2 EnterPay and its regulated financial partners operate a layered transaction monitoring framework. EnterPay's Didit integration includes biometric liveness detection (iBeta Level 1 certified), document tampering detection, and a reusable KYC system that flags previously identified fraudulent identities.
4.3 Where an investigation concludes that a suspicion is founded, a Suspicious Activity Report (SAR) will be filed with the relevant Financial Intelligence Unit. We are legally prohibited from informing any person that a SAR has been filed.
5.1 The User represents and warrants not to be a Prohibited Person and not to be residing in an Excluded Jurisdiction, and to be legally competent and is allowed to access and conclude the Agreement. If the User is, or becomes, a Prohibited Person and/or becomes residing in an Excluded Jurisdiction the User must immediately cease accessing and using the Service.
5.2 The User also represents and warrants that access to and use of the Services is lawful in the country where the User resides in the manner in which the User accesses and uses the Services.
5.3 The User is responsible for compliance with this Policy.
5.4 The User warrants that the User:
5.4.1 Does not access and/or use (parts of) the Service if the User is a Prohibited Person;
5.4.2 Does not access and/or use (parts of) the Service if the User is (or becomes) residing in an Excluded Jurisdiction;
5.4.3 Does not engage in, or knowingly facilitate, any money laundering, terrorist financing, or other illegal activities;
5.4.4 Does not violate any Applicable Law;
5.4.5 Does not act unlawful in any way whatsoever.
5.5 The User is prohibited from accessing and/or using the Service through a network for anonymous communication.
5.6 The User is fully responsible and liable for all actions the User performs using the Service.
5.7 The User indemnifies EnterPay and holds EnterPay harmless against any and all claims (of third parties) relating to or resulting from a breach of this Article.
6.1 All Users of the Platform and Terminal must undergo Know Your Business (KYB) verification. The KYB process includes verification of legal entity information, UBO identification, sanctions and PEP checks, and proof of business activity. EnterPay reserves the right to suspend or terminate access to the Service if a User fails to meet KYB requirements or provides false/incomplete data. Know Your Business (KYB) verification is conducted as part of merchant onboarding using identity-verification technology provided by Didit. Anti-money-laundering and Know Your Customer (AML/KYC) obligations relating to end Customers, including transaction monitoring and regulatory reporting, are performed by EnterPay's licensed third party providers under their own authorisations. Onboarding decisions are made on the basis of verification results. EnterPay does not guarantee approval of any application and is not liable for delays arising from incomplete or pending verification.
6.2 KYC checks are performed by third-party partners when regulatory thresholds are met or where higher-risk activity is identified. The applicable operational thresholds are set out in the AML/KYC Policy. Users are obliged to monitor unusual or large transactions and report them to EnterPay and the competent authorities where applicable.
6.3 EnterPay holds no regulatory licence or registration of any kind in its own name. Any registration, licence number, or authorisation referenced in connection with the Services is attributable to the relevant licensed partner and not to EnterPay. All financial services within the Service are handled through regulated third-party partners. EnterPay performs due diligence on its partners to ensure full compliance with legal requirements, such as AMLD, MiCA, and GDPR. All regulated activities including the custody, exchange, transmission, or settlement of funds or crypto assets, are performed exclusively by licensed partners under their own regulatory authorisations. References to the Services being "powered by licensed payment processors" or providing "settlement through regulated, licensed partners" refer to those licensed partners and not to any licence held by EnterPay.
6.4 EnterPay operates in strict alignment with European Union Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets (the EU Travel Rule).
6.5 For crypto asset transfers exceeding mandatory statutory thresholds (or where required by Applicable Law regardless of transaction value), EnterPay's licensed partners will automatically collect and securely transmit required originator and beneficiary data (including, but not limited to, full legal name, wallet address, account identifiers, national identity number, or physical address) to the counterparty Crypto-Asset Service Provider (CASP).
6.6 Where transactions involve transfers to or from self-hosted or unhosted wallets, the User or Customer may be required to verify ownership or control of the wallet address through supported cryptographic signature mechanisms or risk-based verification methods provided by EnterPay or its licensed partners prior to transaction completion.
6.7 EnterPay and its licensed partners reserve the right to suspend, freeze, reject, or delay any transaction where the accompanying Travel Rule data is incomplete, missing, inaccurate, or indicates a potential match with sanctions, PEP, or high-risk databases. EnterPay accepts no liability for delays or losses resulting from compliance actions taken pursuant to Travel Rule obligations.
6.8 The Service is only available in countries where crypto asset payments are legally permitted. The User is prohibited from using (parts of) the Service in Excluded Jurisdictions.
7.1 The Service may contain links to other applications, platforms, services or websites, that are not managed by EnterPay, such as KYC- and KYB-services. EnterPay has no control or authority over them, makes no warranties or representations in relation thereto and accepts no responsibility therefor or for any loss or damage that may arise from their use. The use of these applications, platforms, services or websites of third parties may be subject to terms of use or terms of service of the relevant third party. EnterPay is not a party thereto.
8.1 During the use of the Service, the User may provide Personal Data to EnterPay. If so, this Personal Data will be saved and processed in accordance with EnterPay's Privacy Statement, and the applicable legislation with regard to the protection of Personal Data.
9.1 If you have any questions or comments about this Policy, please contact us using the contact details below:
EnterPayment OÜ
Registered address: Harju maakond, Tallinn, Kristiine linnaosa, Rahumäe tee 6b-67, 13415, Republic of Estonia
Registration number: 17391111
compliance@enterpay.com