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, investigations and account decisions, our reports to partners, and our cooperation with law enforcement.

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. Our Fraud and Location Controls list the limits.

4. Customer due diligence

Before a customer can add money through Coinflow or send payments:

• Bridge verifies their legal name, date of birth, residential address and Social Security number, and screens them against sanctions and politically exposed persons lists.
• Socure verifies their phone number.
• They must be 18 or older, and a U.S. resident in a state we serve.
• Each person can have only one account.

5. 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.

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.

6. 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.

7. Monitoring

• Limits. Limits on adding money, on declined cards and on top-up attempts.
• Velocity rules. Rules on how often and how much money moves.
• Money from outside the app. Money that arrives from outside Versine is screened and reviewed.

8. Escalation and reporting

We investigate unusual activity and freeze the account’s payment features while we do. The money stays in the customer’s own wallet. We report suspicious activity to Bridge and Coinflow, which file suspicious activity reports with the Financial Crimes Enforcement Network (FinCEN). We cooperate with law enforcement and respond to lawful requests.

9. Record keeping

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

10. 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.

11. Contact

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