1. Section Scope & Legal Intent
2. Mandatory Standards & Operating Requirements
All participants subject to this policy must strictly adhere to the following mandatory standards:
- ePaisay enforces rigorous AML/CFT policies in compliance with FATF recommendations, FinCEN regulations, and EU Anti-Money Laundering Directives.
- All users undergoing financial transactions are automatically screened against UN, OFAC, EU, and UK global financial sanctions and PEP databases.
- ePaisay is legally mandated to report suspicious transaction flows to national Financial Intelligence Units (FIU) via confidential SAR filings without tipping off the user.
3. Explicit Prohibitions & Violation Triggers
The following actions constitute direct non-compliance and trigger automatic intervention by the Warning and Violation System:
- Conducting transactions involving individuals or entities on international sanctions or terror-financing watchlists.
- Utilizing cryptocurrency tumbling, mixing services, or high-risk illicit blockchain addresses.
- Providing false, misleading, or deceptive explanations regarding the ultimate source of funds.
4. Warning & Violation System Enforcement Matrix
Each violation under this section is mapped directly to the automated warning and sanction ladder:
| Violation Code | Offense Description | Detection Method | Severity Tier | Cure Window | Mandatory Sanction |
|---|---|---|---|---|---|
VIOL-3153-01 |
Direct or indirect transaction match against international sanctions watchlist (OFAC/UN). | Sanctions Screening Screening Engine | Tier 4 (Critical) | Immediate | Immediate blocking of funds, permanent account freeze, statutory regulatory filing. |
VIOL-3153-02 |
Inflow of cryptocurrency from verified darknet market, mixer, or ransomware address. | Blockchain AML Analytics Engine | Tier 4 (Critical) | Immediate | Immediate deposit freeze, wallet blacklisting, formal Suspicious Activity Report (SAR) filed. |
VIOL-3153-03 |
Failure to submit requested Source of Wealth / Funds declaration within 5 days. | High-Value Transaction Compliance Gate | Tier 3 (High) | 5 Days | Account withdrawal privileges suspended pending AML documentation. |
5. Platform Safe Harbor & Limitation of Liability
Platform Intermediary Status: ePaisay provides the technological marketplace venue connecting independent counterparties. ePaisay is not a vendor, retailer, agent, or guarantor of any product, service, or transaction governed herein.
Total Disclaimer of Warranties: The platform disclaims all warranties of merchantability, fitness for particular purpose, and non-infringement to the fullest extent permissible by applicable law.
Limitation of Damages: In no event shall ePaisay, its officers, directors, or employees be liable for incidental, indirect, punitive, or consequential damages. Aggregate liability is strictly capped at the lesser of $100 USD or platform fees paid in the preceding three months.
Participant Indemnification: The participant agrees to defend, indemnify, and hold harmless ePaisay against any third-party claims, regulatory penalties, legal fees, or damages arising out of violations of this Section.