AML & Compliance Policy

PrimCard is committed to maintaining a robust compliance framework that helps prevent the misuse of its platform for money laundering, terrorist financing, fraud, sanctions evasion and other forms of financial crime.

Our compliance programme is based on a risk-based approach. Rather than applying the same level of verification to every customer, PrimCard continuously evaluates the level of risk associated with each customer, account and transaction throughout the customer relationship.

This approach allows PrimCard to provide a straightforward onboarding experience whilst maintaining appropriate safeguards designed to identify and manage financial crime risks.

PrimCard combines automated technology with internal compliance procedures to monitor customer activity, assess risk and identify unusual behaviour that may require additional review.

Compliance controls may include automated risk scoring, sanctions screening, blockchain transaction analysis, device intelligence, behavioural analysis, transaction monitoring, fraud detection and other security measures considered appropriate for the services provided.

The level of monitoring applied to an account may change over time based on account activity, transaction patterns, funding behaviour, geographical indicators, security events or other risk factors identified by PrimCard.

Where activity remains consistent with the expected use of the platform and presents a low level of risk, customers may continue using PrimCard without additional verification. Where elevated or unusual risk is identified, PrimCard may request additional information, perform enhanced due diligence, temporarily delay transactions, restrict certain services or suspend account activity until appropriate reviews have been completed.

Compliance reviews may be triggered by a variety of factors, including unusually large transactions, rapid changes in transaction behaviour, repeated failed transactions, suspected fraud, links to high-risk blockchain addresses, sanctions exposure, unusual funding patterns or any activity that appears inconsistent with the normal operation of the account.

PrimCard does not rely solely on onboarding checks. Customer accounts remain subject to continuous monitoring throughout the duration of the customer relationship, allowing risks to be identified as circumstances change over time.

Our compliance framework is designed to balance customer convenience with effective financial crime prevention. PrimCard continually reviews and enhances its internal controls to respond to evolving threats, technological developments, industry best practices and changes in applicable legal or contractual requirements.

Where necessary to protect the platform, PrimCard reserves the right to apply additional compliance measures beyond those described in this policy. This may include requesting further information, conducting manual compliance reviews, limiting account functionality, delaying transactions or terminating customer relationships where continued access presents an unacceptable legal, financial or operational risk.

Compliance decisions are made using a combination of automated systems and human review where appropriate. PrimCard does not disclose the detailed operation of its internal compliance models, fraud detection systems or risk assessment criteria, as doing so could reduce the effectiveness of the controls designed to protect the platform and its users.

PrimCard expects all customers to use the platform lawfully, honestly and in accordance with applicable laws and these policies. Cooperation with reasonable compliance requests forms part of the ongoing relationship between PrimCard and its customers.

PrimCard applies a risk-based customer verification model designed to identify and manage financial crime risks whilst maintaining an efficient onboarding experience for legitimate customers.

Customers are not normally required to complete a traditional document-based identity verification process before creating an account or accessing the standard services available through the PrimCard platform.

Instead, PrimCard applies multiple automated compliance and security controls throughout the customer relationship. These controls help assess the level of risk associated with each customer, account and transaction on an ongoing basis rather than relying solely on checks performed during account registration.

Verification measures may include sanctions screening, politically exposed person screening where appropriate, fraud prevention controls, blockchain analytics, device intelligence, behavioural analysis, transaction monitoring, account risk scoring and other security measures considered necessary to protect the platform.

Risk assessments are dynamic and continue throughout the lifetime of the customer relationship. The level of verification applied to an account may change depending on transaction behaviour, funding activity, geographical indicators, security events, account usage patterns or other risk factors identified by PrimCard.

Where account activity remains consistent with the expected use of the platform and presents a low level of risk, customers may continue using PrimCard without being required to provide additional documentation. Where elevated risk is identified, PrimCard reserves the right to request additional information before allowing certain transactions or services to continue.

Additional verification may include confirmation of identity, proof of address, confirmation of ownership of digital assets, source of funds information, source of wealth information, supporting transaction documentation or any other information reasonably required to complete a compliance review.

The timing of additional verification cannot be predicted and may occur before, during or after account registration, before a transaction is processed or at any stage during the customer relationship.

Failure to provide requested information within a reasonable period may result in temporary restrictions, delayed transactions, suspension of virtual cards, suspension of account access or termination of the customer relationship where appropriate. PrimCard reserves the right to refuse, delay or decline transactions whilst additional verification is being completed.

For security reasons, PrimCard does not disclose the detailed criteria, thresholds or internal risk models used to determine when additional verification is required. Verification decisions are based on a combination of automated systems, internal compliance procedures and, where appropriate, manual review by authorised personnel.

The completion of any verification process does not guarantee continued access to the PrimCard platform. Customer accounts remain subject to ongoing monitoring throughout the duration of the customer relationship.

PrimCard reserves the right to increase or reduce verification requirements at any time in response to changes in applicable laws, regulatory expectations, payment network requirements, operational risks, emerging financial crime threats or changes implemented by our authorised infrastructure providers.

All information collected as part of the verification process is processed in accordance with the PrimCard Privacy Policy and is retained only for as long as necessary to satisfy legal, contractual, operational and security requirements.

PrimCard continuously monitors customer activity to help identify unusual behaviour, reduce financial crime risk and protect the integrity of the platform.

Transaction monitoring forms part of our ongoing compliance framework and applies throughout the entire customer relationship. Monitoring is not limited to account registration and continues for as long as an account remains active.

PrimCard uses automated monitoring systems together with internal compliance procedures to assess transactions in real time and, where appropriate, after they have been completed.

Monitoring may include the review of transaction values, transaction frequency, funding patterns, wallet activity, virtual card funding, spending behaviour, geographical indicators, merchant activity, blockchain transactions, device information and other account activity relevant to the safe operation of the platform.

Transactions may also be assessed against historical account behaviour to identify unusual or unexpected activity that differs significantly from a customer's normal use of the PrimCard platform.

Where a transaction is considered to present a low level of risk, it will normally continue without interruption. Where elevated risk is identified, PrimCard may temporarily delay processing, request additional information, carry out further compliance reviews or apply temporary restrictions while the activity is assessed.

Monitoring may identify activity including, but not limited to: unusually large transactions; rapid increases in transaction volume; repeated funding attempts; multiple declined transactions; unusual merchant activity; transactions involving higher-risk jurisdictions; blockchain activity associated with elevated risk; rapid movement of funds through multiple transactions; activity inconsistent with the customer's normal account behaviour; and suspected fraud or attempted circumvention of platform controls.

The identification of unusual activity does not automatically mean that unlawful activity has occurred. Many alerts are generated for legitimate reasons and are reviewed using a risk-based approach before any action is taken.

PrimCard reserves the right to temporarily delay, decline or suspend transactions while compliance reviews are completed where this is considered reasonably necessary to protect the platform, our customers or our authorised infrastructure providers.

Where appropriate, PrimCard may request additional information relating to a transaction before allowing it to proceed. This may include supporting documentation, confirmation of the purpose of the transaction, source of funds information or any other information reasonably required to complete the review.

For security reasons, PrimCard does not disclose the detailed monitoring rules, transaction thresholds, alert parameters or internal risk models used within its transaction monitoring systems.

Transaction monitoring procedures are reviewed regularly and may be updated without prior notice to reflect changes in financial crime risks, technological developments, regulatory expectations, payment network requirements or operational requirements.

All information collected through transaction monitoring is processed in accordance with the PrimCard Privacy Policy and retained only for as long as necessary to satisfy legal, contractual, operational and security obligations.

PrimCard is committed to preventing its platform from being used in connection with sanctioned individuals, organisations, jurisdictions or other parties subject to applicable sanctions programmes.

As part of our compliance framework, PrimCard applies sanctions screening measures designed to identify and manage sanctions-related risks throughout the customer relationship.

Sanctions screening is not limited to account registration and may be performed before, during or after the creation of a PrimCard account, prior to processing transactions and at any other time considered reasonably necessary.

PrimCard may screen customers, transactions, digital asset activity, wallet addresses and other relevant information against applicable sanctions lists, watchlists and internal risk databases. Screening may also be performed whenever customer information changes, new transactions are initiated or changes occur within applicable sanctions programmes.

If potential sanctions exposure is identified, PrimCard may temporarily delay the affected transaction or restrict account functionality while additional compliance reviews are completed. Where appropriate, PrimCard may request further information or supporting documentation before allowing services to continue.

PrimCard reserves the right to decline transactions, refuse account registration, suspend services or terminate customer relationships where continued access would expose PrimCard, its customers or its authorised infrastructure providers to sanctions-related risks or legal obligations.

For security and compliance reasons, PrimCard is not required to disclose the detailed sanctions screening procedures, screening providers, matching criteria or internal decision-making processes used within its compliance programme.

A potential sanctions match does not automatically mean that a customer is subject to sanctions. Alerts may require further review before a final compliance decision is reached.

Where PrimCard reasonably believes that an account, transaction or customer may be subject to applicable sanctions restrictions, we may take any action considered necessary to comply with applicable legal obligations or protect the integrity of the platform.

PrimCard may cooperate with competent authorities, payment networks, authorised infrastructure providers and other organisations where required by law or where reasonably necessary to investigate potential sanctions-related activity.

Sanctions screening procedures are reviewed regularly and may be updated without prior notice to reflect changes in applicable laws, international sanctions programmes, regulatory expectations or operational requirements.

All information processed as part of sanctions screening is handled in accordance with the PrimCard Privacy Policy and retained only for as long as necessary to satisfy legal, contractual, operational and security requirements.

PrimCard may request information regarding the source of funds or, where appropriate, the source of wealth where this is considered reasonably necessary to comply with our compliance obligations or to manage financial crime risk.

Requests for source of funds or source of wealth information are not made routinely for every customer. Such requests are based on a risk-based assessment of the customer, the transaction or other relevant circumstances identified during ongoing monitoring.

Source of funds refers to the origin of the specific assets or funds used for a particular transaction or series of transactions. Source of wealth refers to the origin of a customer's overall financial position or accumulated assets where this information is reasonably required as part of an enhanced compliance review.

PrimCard may request supporting information where transactions are unusually large, inconsistent with previous account activity, involve higher-risk jurisdictions, present elevated compliance risks or otherwise require additional review.

Supporting information may include transaction records, blockchain transaction references, exchange confirmations, business records, invoices, contracts, proof of asset ownership or any other information reasonably required to understand the origin of the relevant funds.

The information requested will depend on the nature of the transaction and the level of risk identified during the compliance review. PrimCard reserves the right to delay, restrict or decline transactions until requested information has been received and reviewed.

Failure to provide requested information within a reasonable period may result in temporary account restrictions, suspension of services or termination of the customer relationship where appropriate.

The provision of source of funds or source of wealth information does not guarantee that a transaction will be approved. PrimCard will assess all information received as part of its overall compliance review before reaching a decision.

PrimCard does not disclose the thresholds, criteria or internal procedures used when determining whether source of funds or source of wealth information is required.

Information provided during a compliance review will be treated as confidential and processed in accordance with the PrimCard Privacy Policy. Access to such information is restricted to authorised personnel and is retained only for as long as necessary to satisfy legal, contractual, operational and security requirements.

PrimCard reserves the right to request updated source of funds or source of wealth information at any time during the customer relationship where new activity, changing risk factors or applicable legal requirements make further review reasonably necessary.

PrimCard is committed to protecting the platform from fraud, money laundering, terrorist financing, sanctions evasion and other forms of financial crime.

Where PrimCard identifies activity that appears unusual, inconsistent with the expected use of an account or otherwise presents an increased level of legal, financial or operational risk, we may carry out a compliance review before allowing further activity to continue.

A compliance review may be triggered by a single transaction or by a combination of factors identified through our ongoing monitoring systems and internal compliance procedures.

Examples of activity that may require additional review include unusually large transactions, rapid movement of funds, repeated failed transactions, unusual spending patterns, activity involving higher-risk jurisdictions, suspected account compromise, blockchain activity presenting elevated risk, inconsistent account behaviour or any other activity that appears abnormal in the context of the customer's normal use of the platform.

The identification of unusual activity does not automatically indicate unlawful conduct. Many compliance alerts are generated for legitimate reasons and are reviewed using a risk-based approach before any decision is made.

During a compliance review, PrimCard may temporarily delay transactions, restrict account functionality, suspend virtual cards, request additional information or apply other reasonable protective measures while the review is completed.

Customers may be asked to provide supporting documentation, transaction information, confirmation of the purpose of a transaction, source of funds information or any other information reasonably necessary to complete the review.

Failure to cooperate with a compliance review or to provide requested information within a reasonable period may result in continued account restrictions, suspension of services or termination of the customer relationship.

Where PrimCard reasonably believes that activity may involve fraud, financial crime, sanctions violations or other unlawful conduct, we reserve the right to refuse transactions, suspend accounts, terminate services and take any other action considered reasonably necessary to protect the platform and comply with applicable legal obligations.

Where required by law or where reasonably necessary to protect the platform, PrimCard may cooperate with competent authorities, law enforcement agencies, payment networks, authorised infrastructure providers and other relevant organisations in connection with investigations relating to suspected unlawful activity.

For security reasons, PrimCard does not disclose the internal monitoring rules, alert thresholds, investigation procedures or decision-making criteria used when identifying or reviewing suspicious activity.

All information obtained during a compliance review will be handled confidentially and processed in accordance with the PrimCard Privacy Policy. Such information will only be retained for as long as necessary to satisfy legal, contractual, operational and security requirements.

Nothing in this policy prevents PrimCard from taking immediate action where urgent intervention is reasonably necessary to prevent fraud, protect customers, safeguard the platform or comply with applicable legal obligations.

PrimCard provides its services only in jurisdictions where it is legally and operationally able to do so. The availability of the PrimCard platform may vary depending on applicable laws, sanctions programmes, regulatory requirements and the operational capabilities of our authorised infrastructure providers.

PrimCard reserves the right to restrict, suspend or refuse access to the platform in any jurisdiction where providing services would be unlawful, expose PrimCard to unacceptable legal or operational risk or conflict with the requirements of our authorised service providers.

Customers are responsible for ensuring that their use of the PrimCard platform complies with the laws and regulations applicable in the country from which they access or use our services.

You must not use PrimCard for any unlawful, fraudulent or prohibited purpose. Without limitation, prohibited activities include the use of the PrimCard platform for money laundering, terrorist financing, sanctions evasion, fraud, identity theft, the financing of criminal activity, the purchase or sale of illegal goods or services, tax fraud or any activity prohibited by applicable law.

You must not knowingly use PrimCard to receive, transfer or process digital assets derived from unlawful activity or originating from sources that you know or reasonably believe to be connected with criminal conduct.

You must not attempt to circumvent transaction limits, security controls, compliance reviews, account restrictions or any other operational safeguards implemented by PrimCard. You must not provide false, misleading or incomplete information during account registration, compliance reviews or customer support enquiries.

The PrimCard platform must not be used on behalf of another individual or organisation for the purpose of concealing ownership, disguising the origin of funds or avoiding applicable legal or regulatory obligations.

PrimCard reserves the right to prohibit transactions involving particular merchant categories, blockchain addresses, digital assets, jurisdictions, counterparties or transaction types where this is considered necessary to protect the platform or comply with legal, contractual or operational requirements.

Where PrimCard reasonably believes that an account has been used for prohibited activity, we may immediately suspend transactions, restrict account access, freeze virtual cards, terminate the customer relationship or take any other action reasonably necessary to protect the platform and comply with applicable legal obligations.

PrimCard may also refuse to establish or continue a customer relationship where we determine that doing so would expose the platform, our customers or our authorised infrastructure providers to unacceptable legal, financial, operational or reputational risk.

For security reasons, PrimCard does not publish a comprehensive list of all prohibited activities, restricted jurisdictions or internal risk criteria. These may change from time to time in response to changes in applicable laws, sanctions programmes, payment network requirements, operational requirements or emerging financial crime risks.

Nothing in this section limits PrimCard's right to refuse services, decline transactions or terminate customer relationships where such action is reasonably necessary to protect the integrity, security and lawful operation of the PrimCard platform.

PrimCard maintains accurate records relating to customer accounts, transactions, compliance reviews and other activities necessary for the safe and lawful operation of the platform.

Record keeping forms an important part of our compliance framework and helps PrimCard investigate customer enquiries, resolve disputes, prevent financial crime, protect the platform and comply with applicable legal, contractual and operational obligations.

Records maintained by PrimCard may include account registration information, transaction history, virtual card activity, funding records, compliance reviews, verification information, customer communications, fraud prevention records, security logs, blockchain transaction references and other information reasonably required for the operation of the platform.

Where additional compliance reviews are conducted, PrimCard may retain supporting documentation provided by customers, together with the results of any internal assessments carried out as part of the review process.

PrimCard also maintains operational records relating to system activity, account access, authentication events, security monitoring, transaction processing and technical infrastructure where reasonably necessary to support the integrity and security of the platform.

Records are retained only for as long as necessary to satisfy legal, regulatory, contractual, operational and security requirements or to protect the legitimate interests of PrimCard and its customers.

Access to compliance records is restricted to authorised personnel who require access to perform their duties. PrimCard applies appropriate technical and organisational measures designed to protect records against unauthorised access, alteration, disclosure or destruction.

Where records are no longer required, PrimCard will take reasonable steps to securely delete, anonymise or permanently destroy the information in accordance with our internal data retention procedures and applicable legal requirements.

Certain records may remain within encrypted backups, disaster recovery systems or archived security logs for a limited period following deletion where this forms part of PrimCard's normal operational procedures. Such records remain protected and are only retained until the relevant retention period expires.

Customers may request access to certain personal information maintained by PrimCard, subject to applicable laws, our Privacy Policy and any legal or operational restrictions that apply.

PrimCard reserves the right to retain records for longer periods where necessary to investigate fraud, respond to legal proceedings, comply with requests from competent authorities, resolve disputes, recover outstanding balances or protect the security and integrity of the PrimCard platform.

The maintenance of accurate records supports PrimCard's commitment to transparency, responsible compliance and the continued protection of its customers and authorised infrastructure providers.

PrimCard is committed to complying with applicable legal obligations relating to the prevention of financial crime, fraud and other unlawful activity.

Where required by applicable law, PrimCard may report information relating to customer accounts, transactions or other activity to competent authorities, regulatory bodies, law enforcement agencies or other authorised organisations.

PrimCard may also provide information where reasonably necessary to comply with court orders, lawful requests, legal proceedings or other binding legal obligations.

Where permitted by applicable law, PrimCard may share relevant information with payment networks, authorised infrastructure providers, fraud prevention organisations or other parties where such disclosure is reasonably necessary to investigate suspected fraud, protect the platform or prevent financial crime.

PrimCard is not obliged to inform customers that information has been disclosed where doing so would be unlawful, would prejudice an ongoing investigation or would otherwise conflict with applicable legal or regulatory requirements.

Where PrimCard identifies activity that may involve money laundering, terrorist financing, sanctions evasion, fraud or other criminal conduct, we reserve the right to take any action reasonably necessary to protect the platform and comply with our legal obligations. Such action may include delaying or refusing transactions, restricting account functionality, suspending services, terminating customer relationships or reporting relevant information to the appropriate authorities where required.

PrimCard may also cooperate with payment networks, authorised infrastructure providers, financial institutions and other organisations involved in preventing financial crime where such cooperation is lawful and reasonably necessary.

The decision to make a report or disclose information is based upon PrimCard's internal compliance procedures, applicable legal requirements and the specific circumstances of each case. For security and legal reasons, PrimCard does not disclose the internal criteria used when determining whether information should be reported or shared with competent authorities.

Nothing in this AML & Compliance Policy creates an obligation on PrimCard to notify customers before taking action required to comply with applicable law, protect the platform or support lawful investigations.

PrimCard maintains appropriate records of compliance decisions, reports and disclosures where required by applicable law and in accordance with our internal record retention procedures.

PrimCard may amend, update or replace this AML & Compliance Policy from time to time to reflect changes in applicable laws, regulatory expectations, financial crime risks, operational requirements or the services provided through the PrimCard platform.

As our platform, technology and compliance framework continue to evolve, this policy may be updated to ensure that it accurately reflects the way PrimCard manages compliance risks and protects the integrity of its services.

The latest version of this AML & Compliance Policy will always be available on the PrimCard website together with the date on which it became effective.

Where changes materially affect the operation of our compliance framework or your rights and obligations, PrimCard may provide additional notice through the website, customer dashboard, email or other communication channels where reasonably practicable.

Your continued use of the PrimCard platform following the publication of an updated AML & Compliance Policy constitutes your acknowledgement of the revised policy to the extent permitted by applicable law. If applicable law requires your consent before certain changes become effective, PrimCard will obtain such consent before implementing those changes.

Previous versions of this AML & Compliance Policy may be retained for legal, regulatory, audit and record-keeping purposes.

If you have any questions regarding this AML & Compliance Policy or PrimCard's compliance framework, you may contact our customer support team through the contact details published on the PrimCard website or through your registered PrimCard account.

PrimCard will make reasonable efforts to respond to compliance-related enquiries promptly. For security, legal and operational reasons, we may be unable to disclose details of our internal monitoring procedures, fraud detection systems, sanctions screening methods or compliance decision-making processes.

Where your enquiry relates to an ongoing compliance review, transaction delay or account restriction, PrimCard may request additional information to verify your identity before discussing account-specific information.

Nothing in this section limits PrimCard's rights or obligations under applicable law or prevents customers from contacting a competent authority where such rights are provided by law.