Anti-Money Laundering (AML) Policy

PapelSoftware LLC ("PapelShip", "we") does not allow the platform to be used for money laundering, terrorist financing, fraud or sanctions evasion. This policy sets out how we prevent it. It works together with our KYC Policy and Acceptable Use Policy.

• Seller-connected gateways: card payments go from the buyer to the seller through a payment account the seller holds in their own name. The provider applies its own AML controls. PapelShip does not receive, hold or transmit these funds.
• Cryptocurrency: payments go wallet to wallet, from the buyer straight to the seller's own wallet. PapelShip never takes custody of crypto, never holds private keys and does not exchange or transmit virtual currency.
• PapelPay (not live yet): once PapelPay launches, card payments will be processed by a licensed payment partner under PapelShip's platform account, and PapelShip will pay sellers out after deducting its commission. The controls below apply in full to PapelPay.

• Customer due diligence: every PapelPay seller is verified under our KYC Policy before taking card payments, including beneficial owners of businesses.
• Sanctions: we do not serve persons or entities on sanctions lists, including those of OFAC, the UN, the EU and the UK, or businesses in comprehensively sanctioned jurisdictions.
• Prohibited businesses: stores may only sell products allowed by our Acceptable Use Policy and by our payment partner's prohibited and restricted business list.
• Transaction monitoring: PapelPay transactions will be monitored for unusual patterns, such as volumes that don't match the declared business, rapid refunds, split payments, high chargeback rates or payouts to changing accounts.
• Payout safeguards: payouts go only to a bank account in the verified seller's own name and can be held while a review is open.
• Risk-based reviews: higher-risk stores receive enhanced due diligence, such as proof of source of funds, supplier invoices or more frequent reviews.

When we find activity that may involve money laundering, terrorist financing, fraud or sanctions evasion, we may suspend the store, hold the payouts linked to that activity while we review it, close the account and share information with our payment partners and with the competent authorities where the law requires or allows it. We will not tell a seller about a report when the law forbids it.

Anyone can report a suspicious store through our abuse report form or to [email protected].

Verification records and transaction records are kept for at least five years after an account closes, or longer where the law requires. This policy is reviewed at least once a year and whenever our payment services change.

Compliance questions can be sent to [email protected]. Company details are on our company page.