AML & Compliance Policy

1. Our approach

CoinAvio holds funds on behalf of merchants, so we take steps to prevent the Service from being used for money laundering, terrorist financing, fraud or sanctions evasion. We follow a risk-based approach: checks increase with the risk of a merchant, a payment or a withdrawal, and most payments settle without any manual step.

This policy describes those checks. It may change as laws and risks change.

2. Merchant onboarding and review

Every merchant account starts with email verification. Before live payments are enabled, we review the business: its name, its website and what it sells, against our Acceptable Use Policy. Merchants can also verify ownership of their domains by DNS TXT record, meta tag or verification file; a verified domain is needed to send buyers back to the merchant’s site after a live payment.

We may ask for more information or documents about the business, its owners or the source of its funds, and we may refuse or end a relationship that we consider too risky.

3. Sanctions

We do not provide the Service to persons or entities on United Nations, European Union, United Kingdom or United States sanctions lists, to anyone acting on their behalf, or in jurisdictions where providing the Service is prohibited.

Live payments and withdrawal destinations are automatically checked against the sanctioned digital-currency addresses published by the U.S. Treasury’s Office of Foreign Assets Control (OFAC). Funds linked to a sanctioned address are held for review, and we do not send withdrawals to sanctioned addresses.

4. Payment screening

For live payments on invoices at or above a USD threshold set by our compliance policy, we screen the sending address with a blockchain analytics provider. The provider estimates how closely the funds are linked to illicit activity, such as sanctioned entities, scams, darknet markets or stolen funds. A recent result for the same address may be reused for a limited period.

Payments assessed as low or moderate risk settle normally. Payments assessed as high risk are held for review. Test invoices are not screened.

5. Held payments

While a payment is being screened or reviewed:

• the funds stay in custody and are not credited to the merchant’s balance;
• the invoice keeps its pending status and does not expire. The API shows reviewReason AML_SCREENING or AML_REVIEW, and each held payment is marked held;
• the buyer sees that the payment was received and is under review;
• no invoice.paid webhook is sent until the payment is released.

If the payment is released, it is credited and the invoice completes as normal, with the usual webhooks. If it is rejected, the funds are not credited, the invoice shows AML_REJECTED and is not paid, and we handle the funds as the law requires. Depending on the case, that can mean returning them, keeping them frozen or reporting them to the authorities.

Merchants should never fulfil an order based on a reviewReason value. Fulfil only on PAID or OVERPAID.

6. Withdrawal checks

Before a payout, each withdrawal destination is checked against the OFAC list and screened by the blockchain analytics provider; screening results are refreshed periodically. For USDT on networks where the token issuer can freeze addresses, we also check whether the destination is frozen, because funds sent there could be stranded. A destination flagged as high risk or sanctioned goes to manual review, and the withdrawal may be refused.

Independently of screening, a newly added withdrawal address has a cooling period during which withdrawals to it are approved manually, and larger or unusual withdrawals are also approved manually.

7. Ongoing monitoring

We review accounts when something suggests a risk, such as payments that do not match the business we approved, unusual volumes, or attempts to avoid our checks. While we look into it, we may ask questions, apply limits, hold funds or suspend the account.

8. Record keeping

We keep merchant review records, screening results, review decisions and payment and withdrawal records for as long as the law requires, including after an account is closed. See the Privacy Policy.

9. Requests from authorities

We cooperate with lawful requests from law enforcement agencies, courts and regulators. Send requests to support@coinavio.com. The law may prevent us from telling a merchant about a request or an investigation.

10. If your funds are held

Merchants: contact support@coinavio.com with the invoice ID. We may ask about the payment, your relationship with the buyer or your business. We cannot always share the details of a review or say in advance how long it will take.

Buyers: if your payment shows as under review, do not send it again. Contact the merchant, or contact us with the invoice ID and transaction hash.