Documents

TgPay Crypto AML/KYC Policy

Revised September 10, 2026.

1. Purpose of this policy

This policy describes identity and transaction checks in TgPay Crypto, source of funds verification, and restrictions that may apply as a result of a review.

These checks aim to combat money laundering (AML), terrorist financing (CFT), fraud, and evasion of applicable sanctions. Identity verification is referred to as KYC, and transaction analysis as KYT.

In this policy, “we” and “the service” mean TgPay Crypto.

The extent of a review depends on the nature of the transaction, available information, and risk. Being technically able to open the app or perform an action does not override applicable legal restrictions.

2. When verification is required

In the current version of the wallet, document verification is not required to sign in for the first time. It may be needed to access certain features, review a restriction, or check a transaction. The relevant request and available steps are shown in the app.

Verification includes confirming your phone number through Telegram, providing basic personal information, and checking an identity document. We may request your first and last name, patronymic if applicable, date of birth, country of residence, document images, a selfie, and a liveness check. Proof of your residential address or source of funds may also be required.

Provide your own valid documents and accurate information. Forged documents, impersonation, and using someone else's data to pass verification are not allowed. If your information contains an error or has changed, contact the support team.

Checks involve external verification services and may include a manual review. Depending on the outcome, you may need to try again or provide more information.

3. Identity checks and risk assessment

During verification, identity information may be checked against sanctions sources, information on politically exposed persons (PEPs), and publications containing risk-related information. A potential match requires a review of the context: a matching name alone does not prove that it is the same person.

Further review may be required if information is inconsistent, documents cannot be reliably verified, or signs of abuse are found. PEP status alone does not imply unlawful conduct.

Device, session, and activity information is also used to prevent abuse. This policy does not treat a shared IP address or use of the same device as independent proof of a violation. Reviews consider all available data together.

You must not use linked accounts, nominee recipients, or artificial splitting of transactions to bypass limits and checks. Authorized integrations through Merchant API and MCP operate within their granted permissions and remain subject to applicable service rules.

4. Transaction screening

The wallet screens incoming deposits and withdrawal addresses. Depending on the transaction, analysis covers the source and destination of funds, available blockchain history, transaction amounts and sequences, address connections, and risk indicators. We use internal tools, public data, and external blockchain analysis services for this purpose.

Further review may be triggered by information linking funds to sanctioned addresses, theft, hacks, fraud, or other unlawful activity, or by unusual patterns of fund movement. A risk assessment informs a decision; it is not equivalent to a court's determination of the source of funds.

A review may result in the transaction going through, rejection of a withdrawal to a specific address, a deposit being put on hold before crediting, or a request for more information. If a required check is temporarily unavailable, the transaction may be deferred until it can be completed.

Address screening is not intended for testing large numbers of addresses through withdrawal attempts. Repeated attempts to use blocked addresses may lead to a fee for subsequent checks, as explained in advance by the service. This fee does not pay for unblocking and does not guarantee that the transaction will go through.

5. Verifying the source of funds

If the available information is insufficient to review a transaction, you may be asked to explain where a specific amount came from and provide supporting documents. This is known as source of funds (SoF) verification.

Depending on the situation, suitable documents may include:

a statement or transaction history from an exchange account;
confirmation of a withdrawal from another platform;
a bank statement showing the relevant incoming payment;
a contract, invoice, pay stub, or property sale document;
other documents that connect the source of funds to the transaction under review.

Documents must match the amount, timing, and circumstances of the transaction. Source of funds verification may require identity verification first.

If the relevant step is available under More → Verification, upload your documents there. If the step is missing or does not open, contact the support team for further instructions. Do not share documents with outsiders who promise to speed up the review.

Incomplete or conflicting information may lead to another request or the restriction remaining in place. Approval of documents does not override separate grounds that prevent a transaction from going through.

6. Deposit holds and account restrictions

A deposit on hold cannot be spent until a decision is made. A hold alone does not mean the deposit has been confiscated.

Holding a specific deposit and restricting an account are different measures. Putting one incoming deposit on hold does not automatically block all other funds. A separate restriction may affect outgoing transactions or access to certain features.

Identity verification, source of funds verification, and reconsideration of the deposit itself are also separate reviews. Completing one does not guarantee that all restrictions will be lifted. Some cases require a separate specialist review.

If you believe a restriction is a mistake, contact the support team. Include the transaction, asset, network, amount, and transaction ID if available. Do not send another deposit to try to speed up the review.

7. Sanctions and legal restrictions

We take applicable sanctions restrictions into account when reviewing users and transactions. If grounds for further review are identified, a transaction or access to the relevant funds may be temporarily restricted.

Decisions take account of review results and applicable law. If funds are subject to a mandatory freeze, dealing with them, including returning them, is possible after the necessary authorization is obtained or the relevant prohibition ends.

The availability of certain features may depend on legal requirements in the user's country. Being able to open the app does not in itself establish that every transaction is permitted.

8. Withdrawals and returns of funds

Access to the funds under review may be restricted during the review. Contact the support team to request consideration of a withdrawal or return.

The possibility of a return is reviewed individually when the following conditions are met:

the applicant's identity and entitlement to the funds have been confirmed;
the required documents have been provided and the relevant checks completed;
the return is permitted by applicable law and restrictions in force.

If a return is approved, its procedure and any fees are agreed on before the transaction. Completing verification does not in itself remove the restrictions described in section 7.

9. Age and accurate information

The service is intended for adults. Verification checks that you are at least 18 years old. Failure to meet the age requirement may prevent you from completing verification and accessing features that depend on it.

Providing someone else's documents or handing your account to another person to bypass verification is not allowed. Requests involving a minor's data, impersonation, or loss of access require individual review. This policy does not impose an automatic hold on funds until adulthood or their unconditional seizure.

10. Official requests and confidentiality

The service reviews official requests from competent authorities and discloses information where an applicable lawful basis exists. Mandatory reporting procedures for suspicious transactions depend on the status of the entity operating the service and applicable law.

Official requests can be sent to law@tgpaycrypto.com, identifying the authority, the grounds for the request, and details that identify the relevant transaction or account. This does not mean data is automatically disclosed to anyone who asks.

Information about the data processed, recipients, protection, and data-related requests is provided in the Privacy Policy. External services may be involved in checks. Retention periods are determined separately for different data categories, taking applicable obligations into account.

11. Support and reconsideration

For questions about verification, a deposit on hold, or restrictions, open More → Support in the app.

Explain what happened and which decision you disagree with. We may request information needed to review your request. How fully we can explain the reasons for a restriction may depend on legal requirements and the need to protect screening procedures.

No outsider can lift a restriction for a fee. Do not share your PIN, one-time codes, API tokens, or secret recovery phrases for external wallets.

12. Changes to this policy

The current version will be available in the app with its effective date. When rules change, we will follow the notification procedures required by applicable law and obtain consent if necessary.