AML POLICY

Effective Date: 01.05.2026
Provider: 2Way OU, doing business as Proovl
Website: Proovl.com


1. Overview

This AML Policy explains how Proovl reviews payments and transactions to reduce fraud, money laundering, sanctions, and other financial crime risks.

Proovl may use third-party AML and transaction risk tools to screen payments, wallets, transactions, and related activity.

By making a payment to Proovl, you agree to this AML Policy.



2. Transaction Risk Review

Proovl may review any payment or transaction before Credit is added to your account balance.

A transaction may be delayed, rejected, held, returned, or require additional verification if Proovl considers it suspicious, high-risk, inaccurate, incomplete, or otherwise unacceptable.



3. Risk-Based Handling

If a transaction receives an overall risk score greater than 35%, Proovl may apply an additional review or require KYC before processing the payment.

If the high-risk portion of a transaction exceeds 1%, Proovl may hold the transaction and require KYC before processing, crediting, or returning the payment.

Proovl may refuse to credit or accept any transaction that presents an unacceptable AML, sanctions, fraud, legal, operational, or reputational risk.



4. KYC and Return of Funds

If KYC is required, Proovl may request identity verification, payment verification, source-of-funds information, supporting documents, or other information.

If KYC is not completed to Proovl’s satisfaction, Proovl may refuse the transaction, restrict the account, suspend services, or refuse future service.

Where legally and technically possible, Proovl may return held funds after completing the required review.

Any returned amount may be reduced by blockchain fees, network fees, bank fees, processor fees, risk-review costs, or other transaction-related costs.



5. Payment Accuracy

You are responsible for making payments accurately and in accordance with the payment instructions shown by Proovl.

Incorrect, incomplete, underpaid, overpaid, expired, high-risk, or otherwise irregular payments may be delayed, rejected, held, returned, or require additional verification.

Proovl is not responsible for losses, delays, fees, exchange-rate differences, blockchain fees, network fees, bank fees, processor fees, or other costs caused by inaccurate or irregular payments.



6. Changes to This Policy

Proovl may update this AML Policy from time to time.

The updated policy will be published on Proovl.com or made available inside your Proovl account.

Your continued use of Proovl after the updated policy becomes available means that you accept the updated policy.