Anti-Money Laundering and Counter-Terrorist Financing Policy

1. Scope and our partners

Versine is software. It is not a bank or a money transmitter: it does not hold customer funds, take custody of them or exchange currency. Every payment is approved by the customer from their own wallet, one at a time or through a payment rule they approved.

Money moves in and out of Versine through licensed partners: Bridge for identity verification and payouts to bank accounts, and Coinflow, with Brale, for adding money. Each runs its own Bank Secrecy Act and anti-money laundering program for the services it provides. Versine runs the controls in this policy on top of theirs. Our partners’ licenses are listed on our licenses page.

2. Compliance Officer

A co-founder of Versine is our designated Compliance Officer, responsible for this program: its controls, enhanced due diligence, investigations and account decisions, our cooperation with law enforcement, and our reports of suspicious activity to partners. The Compliance Officer is our designated reporting authority (section 10). When the Compliance Officer is unavailable, another co-founder acts in their place.

3. A risk-based approach

We apply stronger controls where risk is higher. New accounts, and any account with a dispute or fraud alert, have lower limits on adding money than established accounts, and every card payment is screened for fraud. Customers who present higher risk go through enhanced due diligence (section 5). Our Fraud and Location Controls list the limits.

4. Customer due diligence

Every customer goes through identity verification as part of sign-up in the Versine app:

• Bridge verifies their legal name, date of birth, residential address and Social Security number, and screens them against sanctions and politically exposed persons lists.
• Their mobile phone number is verified with a one-time code, through Socure (or by Versine, when Socure cannot check the number).
• They must be 18 or older, and a U.S. resident in a state we serve.
• Each person can have only one account.

When verification is completed. Verification is complete when Bridge approves the customer. Adding money through Coinflow, paying out to a bank account, and payment links that pay out to a bank all require that approval. While Bridge is still checking a customer, they can pay other Versine customers, and send payment links that can only be claimed into a Versine account, under lower limits: $250 per payment, $500 per day and per week, and $2,000 per month.

If Bridge refuses, pauses or offboards a customer, all of their payment features stop. If Bridge refuses or holds a customer for a fraud, sanctions, watchlist or politically exposed person reason, we also open a compliance case.

5. Enhanced due diligence

When it applies. A customer goes through enhanced due diligence, and is treated as high risk until the review is decided, when:

• Bridge flags them for a fraud, sanctions, watchlist or high-risk reason, or we learn they are a politically exposed person (section 6).
• Our sanctions screening finds a possible match.
• A card payment draws a fraud alert or chargeback, or a bank debit is returned or disputed.
• Money arrives in their wallet from outside Versine and our review cannot explain where it came from.
• Their activity does not fit their profile, or repeatedly triggers our monitoring rules (section 9).

What we do. A sanctions match, a Bridge flag or a payment dispute freezes the account’s payment features automatically, and we can freeze them for any other review; the money stays in the customer’s own wallet. The Compliance Officer:

• Reviews the customer’s identity verification results, payment history, counterparties, and device and IP address history, and searches public news sources for adverse information about them.
• Asks the customer for more information where needed, such as the source of their funds and the purpose of their payments, and, through Bridge, for identity documents. If the customer does not answer within 30 days, we close the account.
• Decides, within 10 business days of the trigger, to approve the account (with restricted features or closer monitoring where needed), close it, or report the activity (section 10).
• Records the evidence reviewed, the decision and its reasons in the compliance case.

Accounts approved after enhanced due diligence are reviewed again at least every 6 months.

6. Politically exposed persons

A politically exposed person (PEP) is someone who holds or has held a prominent public position, in the United States or abroad, or a member of their family or a close associate.

• Screening. Bridge screens every customer against PEP lists when it verifies them, before they can add money or pay out to a bank. We screen every customer against the OFAC SDN list at sign-up, whenever their profile changes and before every payment, and refresh our copy of the list every 6 hours.
• A flag from Bridge. If Bridge refuses or holds a customer for a PEP or watchlist reason, we block the account’s payment features automatically and open a compliance case. The account stays blocked unless Bridge approves the customer. If Bridge later pauses or offboards a customer, we block them automatically.
• Vetting. For a customer we learn is a PEP, from Bridge, from the customer or from our own review, we carry out enhanced due diligence (section 5), including the source of their funds and of their wealth. The account can be used only if the Compliance Officer and a second co-founder both approve it, and the approval is recorded in the compliance case.
• Ongoing. We review approved PEP accounts at least every 6 months, and close an account whose activity does not match what the customer told us.

7. Sanctions screening

We screen against the U.S. Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list:

• Each customer’s name and date of birth at sign-up and whenever their profile changes.
• Both customers and both wallet addresses before every payment between Versine customers.
• The recipient before every scheduled payment and every payment to a trusted contact.
• Each person who claims a payment link, on their name, date of birth and IP address, before the claim pays out.
• The owner of every bank account a payout goes to. Bridge also screens every payout.

We refresh our copy of the SDN list every 6 hours. Requests from embargoed countries and regions are blocked. A match blocks the account’s payment features and opens a compliance case.

8. Prohibited uses

Our Terms of Service (Section 8) prohibit using Versine for illegal activity, including fraud, money laundering, terrorist financing and sanctions evasion, and for other uses, such as receiving payments as a business or paying on behalf of another person.

9. Transaction monitoring

Automated rules run on every payment, before it is made:

• Account limits. Limits on each payment and on the total sent per day, week and month, by amount and by number of payments, lower until Bridge approves the customer.
• Velocity rules. Limits on payments per hour, on new recipients per day, on paying many different people in a short time, and on receiving from many different people in a short time, with a lower daily amount for new accounts. A payment that breaks a rule is refused.
• Adding money. Limits on each top-up and on the total added over rolling periods, lower for new accounts, and limits on declined cards and checkout attempts. Coinflow’s fraud engine screens every card payment, and a fraud alert, chargeback or bank return freezes the account.
• Screening. Sanctions screening before every payment (section 7), and screening and manual review of money that arrives from outside Versine.

Our team reviews:

• Open compliance cases, every business day.
• Refused payments and alerts, every week, for patterns such as amounts kept just under limits, money moving in and straight out, or many unrelated counterparties.
• Our limits and rules, at least every quarter.

10. Suspicious activity reporting

Reporting authority. The Compliance Officer decides what is reported and makes every report. Versine is not itself a money transmitter. We report suspicious activity to our licensed partners, Bridge and Coinflow (with its licensed partner, Brale), which decide under their own anti-money laundering programs whether to file a suspicious activity report with the Financial Crimes Enforcement Network (FinCEN).

1. Identify. Suspicious activity comes from our monitoring (section 9), screening, partner alerts, customer reports, our team, and requests from law enforcement.
2. Escalate. Anyone at Versine who sees possible suspicious activity tells the Compliance Officer the same business day, and a compliance case is opened.
3. Investigate. We can freeze the account’s payment features while we investigate. The Compliance Officer reviews the activity as in section 5 and decides within 10 calendar days of detection whether it is suspicious, recording the reasons.
4. Report. Within 2 business days of that decision, we report the activity to Bridge and Coinflow with the customer’s details, the transactions involved, and why we believe they are suspicious, so they can act within FinCEN’s deadlines. Activity that may involve terrorist financing or an ongoing crime is reported to them and to law enforcement at once.
5. Follow up. We review reported accounts at least every 90 days, and report again or close the account if the activity continues.

We never tell a customer, or anyone outside the investigation, that their activity has been reported. Case files are kept for at least 5 years. We cooperate with law enforcement and respond to lawful requests.

11. Record keeping

We keep identity verification results, payment authorizations, screening results, compliance cases and transfer records for at least 5 years.

12. Training and independent review

Everyone at Versine with access to customer data or payments is trained on this policy every year. The program is reviewed independently every year.

13. Contact

Oversine, Inc., 2261 Market Street STE 68058, San Francisco, CA 94114 · legal@versine.com