Effective Date: February 5, 2026
Last Reviewed: February 5, 2026
This Anti-Money Laundering ("AML") and Know Your Customer ("KYC") Policy ("Policy") sets out PoolSpace's approach to preventing illicit financial activity and ensuring compliance with applicable anti-money-laundering, counter-terrorist financing, identity verification, and related laws and regulations. This Policy supplements PoolSpace's Terms & Conditions and Privacy Policy.
The objectives of this Policy are to:
- Prevent PoolSpace being used to facilitate money laundering, terrorist financing, fraud, or other illicit conduct.
- Establish minimum standards for customer due diligence (CDD) and identity verification.
- Ensure compliance with applicable laws, regulations, and industry best practices.
- Protect PoolSpace, its users, contributors, payment partners, and other stakeholders.
This Policy applies to:
- All users of the PoolSpace platform, including Organisers, Beneficiaries, Contributors, and any associated accounts.
- All Pools created, contributions collected, payouts initiated, and related financial activity.
- All operations conducted through or on the PoolSpace platform.
The following terms have the meanings set out below:
- AML/CTF Laws: Anti-Money Laundering and Counter-Terrorist Financing laws and regulations applicable to PoolSpace and its users, including financial crime, sanctions, and reporting obligations.
- Beneficiary: The individual or entity designated to receive funds collected from a Pool.
- CDD (Customer Due Diligence): Processes and procedures for identifying and verifying users, assessing risk, and monitoring user activity.
- High-Risk Activity: Transactions, behaviours, jurisdictions, or user types that present elevated risk of money laundering or financial crime.
- Organiser: The natural person who creates and manages a Pool on PoolSpace.
PoolSpace is committed to complying with all applicable AML/CTF Laws, including but not limited to:
- Identity verification requirements
- Customer due diligence (CDD) and enhanced due diligence (EDD)
- Suspicious transaction reporting
- Sanctions screening against relevant watchlists
- Recordkeeping and audit trails
Before accepting contributions or initiating payouts, PoolSpace must verify the identity of Organisers. Verification may include:
- Full legal name
- Government-issued identification (e.g., national ID, passport)
- Date of birth
- Contact information
- Selfie or liveness check (if required)
- Verification of bank account ownership
When a Pool is created for a third-party Beneficiary, PoolSpace must verify:
- Full legal name of Beneficiary
- Bank account details and holder name
- Relationship between Organiser and Beneficiary (if applicable)
- Additional identity documentation when required
PoolSpace adopts a risk-based approach to AML/KYC. The level of due diligence will depend on:
- The size and frequency of contributions
- Source jurisdictions of contributors
- Whether the Organiser and Beneficiary are the same person
- Indicators of suspicious or unusual activity
Higher-risk situations may require enhanced due diligence (EDD), including additional documentation or manual review.
Verification of identity and bank accounts may be performed using:
- Third-party identity verification services
- Bank account validation APIs
- Government databases
- Public records and watchlist screening
PoolSpace may refuse or suspend services if verification is unsuccessful or data is inconsistent.
PoolSpace screens users and entities against applicable sanctions lists, including but not limited to:
- United Nations Security Council sanctions lists
- Local and international government or regulatory sanctions lists
Users appearing on a sanctions list may have accounts suspended, contributions blocked, and information reported to authorities.
PoolSpace conducts ongoing monitoring of Pools and user activity to identify patterns that may indicate financial crime, including:
- Unusual contribution amounts
- Rapid changes in contribution behavior
- Multiple Pools created by same user with inconsistent information
- Attempts to manipulate verification processes
PoolSpace will report any suspicious activity to relevant authorities, regulators, or law enforcement where required by law or regulation.
PoolSpace retains records of all user identity verification data, transaction histories, verification responses, and audit trails in accordance with applicable law and regulatory requirements.
In cases where money laundering, fraud, or financial crime is suspected or confirmed, PoolSpace may take one or more of the following actions:
- Suspend or terminate user accounts
- Freeze Pools or pending payouts
- Reverse or block transactions
- Refer matters to law enforcement or regulatory bodies
- Share information with payment partners or other third parties for risk mitigation
Users agree to:
- Provide accurate and truthful information
- Promptly respond to verification requests
- Comply with all AML and KYC procedures
- Not attempt to circumvent verification, identity, or security processes
Failure to cooperate may result in suspension or termination of account and denial of access to services.
PoolSpace will periodically train staff and implement internal controls to:
- Maintain awareness of AML/KYC obligations
- Monitor compliance with this Policy
- Update risk frameworks and verification procedures
This Policy will be reviewed and updated as necessary to reflect changes in:
- Applicable laws and regulations
- Industry standards
- Operational requirements
- Risk assessments
PoolSpace will ensure that users are notified of significant changes in a timely manner.
By using the PoolSpace platform, users acknowledge that they have read, understood, and agree to comply with this AML/KYC Policy. Continued use of the platform signifies acceptance of this Policy and any future amendments.