Anti-Money Laundering and Counter-Terrorist Financing Policy (AML/CFT)

This Policy is an integral part of the User Agreement of the Paynote service (https://paynote.eu). We adhere to strict international standards to prevent the use of our platform for illegal purposes.

1. Legal and Regulatory Framework

Paynote (Registration Number B16832941, Spain) operates in accordance with:

Regulation (EU) 2023/1114 (MiCA) — the current EU legislation on Markets in Crypto-Assets.
Directive (EU) 2018/843 (5AMLD) and subsequent updates on the prevention of money laundering.
Spanish Anti-Money Laundering Law and FATF recommendations.

2. User Verification (KYC)

To ensure transaction security, Paynote implements CDD (Customer Due Diligence) procedures.

For Individuals: Provision of a government-issued identity document (Passport/ID), proof of residence, and biometric verification (liveness check/selfie).
For Legal Entities: Full identification of Ultimate Beneficial Owners (UBO), provision of corporate registration documents, and ownership structure.
Screening: All users are screened against international sanction lists (OFAC, EU, UN, HMT) and Politically Exposed Persons (PEP) lists.

3. Cryptocurrency Transaction Monitoring (AML Screening)

Every incoming and outgoing transaction undergoes automatic verification by specialized AML screening services.

3.1. Risk-Score Assessment Model

To assess asset “cleanliness,” the service utilizes an automated Risk-Score model that analyzes address connections to illicit activities. The risk level is measured on a scale from 0% to 100%.

The systеm applies the following thresholds:

0% – 40%: Low Risk (Green Zone). Transactions are processed normally.
41% – 69%: Medium Risk (Yellow Zone). Additional information regarding the exchange purpose may be requested.
70% and above (0.7): High Risk (Red Zone). Upon reaching this threshold, the exchange is automatically blocked for in-depth AML control.

3.2. Incoming Transactions and Blocking

If an incoming transaction has a Risk-Score of 70% or higher, or has a direct link to prohibited sources (Darknet, Mixers, Sanctions):

The crediting of funds is suspended.
The User is requested to provide Source of Funds (SoF) documentation, after which a refund is processed.
The investigation period may take up to 10 working days.
In the event that the User refuses to provide the requested information, details regarding the transaction and suspicious activity will be reported to the relevant regulatory authorities in compliance with AML/CFT regulations.
If the nature of the risks does not mandate reporting to regulatory authorities, the assets will be returned to the owner.

3.3. Withdrawal to High-Risk (“Dirty”) Wallets

If the recipient’s wallet address has a Risk-Score exceeding 70%:

The payout is suspended. The service will request the client to provide a different (“clean”) wallet address.
If a clean address cannot be provided or the user refuses to do so, the service will issue a refund (minus network and service fees) following identity verification of the sender.

3.4. AML Pre-checking Service

To minimize risk, Users may perform a paid AML check of their assets before initiating an exchange via Live Chat or the dedicated website section.

4. Risk-Based Approach

The service reserves the right to set limits, request additional documents, or refuse service without explanation if a violation of this Policy is suspected.

5. Privacy and Reporting

Data is stored in accordance with GDPR. Paynote is obliged to report suspicious transactions to law enforcement authorities (e.g., SEPBLAC) without notifying the User.

Contact Us
For AML compliance inquiries: [email protected]

AML Policy