Commitment and standards
Halfin is committed to compliance with AML, counter-terrorism financing (CTF), and sanctions regulations applicable to its operations. We align our procedures with the recommendations of the Financial Action Task Force (FATF), with the sanctions regimes of the United States Office of Foreign Assets Control (OFAC), the United Nations Security Council, the European Union, and the United Kingdom, and with other applicable international standards.
We adopt a risk-based approach, applying controls proportionate to the risk profile of each Merchant, transaction, and counterparty.
Scope of application
This Policy applies to:
- All Merchants onboarded to the Services and their beneficial owners, directors, and authorized personnel.
- All transactions processed through the Services.
- All Halfin personnel, contractors, and third-party providers handling Merchant data or transactions.
Customer due diligence (KYB)
Before establishing a business relationship, every prospective Merchant undergoes Know Your Business (KYB) verification. KYB includes, at minimum:
- Verification of legal entity registration, including company name, registration number, and registered office.
- Identification of directors, ultimate beneficial owners (typically holding 25% or more, or otherwise exercising control), and authorized signatories.
- Verification of identity and address for each director and beneficial owner, using government-issued identification and proof of address.
- Documentation of business model, including products and services offered, target verticals, and expected transaction profile (volume, frequency, geography, counterparties).
- Documentation of source of funds and, where relevant, source of wealth.
- Documentation of regulatory or licensing status, where applicable to the Merchant's activities.
- Screening against international sanctions, PEP, and adverse media databases.
KYB approval
No Merchant is granted live access to the Services until KYB has been completed to Halfin's satisfaction and written approval has been issued by the compliance team.
Enhanced due diligence
Enhanced Due Diligence (EDD) applies to Merchants and transactions presenting higher money laundering or terrorism financing risk, including but not limited to:
- Merchants operating in high-risk verticals (where permitted, including iGaming and similar).
- Merchants with complex ownership structures, including trusts, nominee arrangements, or layered holding companies.
- Merchants connected to politically exposed persons (PEPs) or their close associates.
- Merchants located in or transacting with higher-risk jurisdictions.
- Transactions exhibiting patterns inconsistent with the declared business profile.
- Large transactions, unusually structured transactions, or transactions involving privacy-enhancing techniques.
EDD measures
EDD may include additional documentation requests, source-of-funds verification, on-call or video verification of beneficial owners, on-site review where appropriate, and senior compliance approval before continuing the relationship.
Ongoing monitoring
Halfin conducts ongoing transaction monitoring designed to detect activity inconsistent with declared business purpose or indicative of money laundering, terrorism financing, sanctions evasion, fraud, or other financial crime. Monitoring includes automated rule-based screening, behavioral analytics, and human review of flagged activity.
Halfin conducts periodic reviews of Merchant profiles, frequency depending on risk classification.
Merchants must promptly notify Halfin of any material change to:
- Legal entity structure.
- Beneficial ownership.
- Business model, products, or target geographies.
- Regulatory or licensing status.
- Authorized personnel.
Sanctions screening
Halfin screens Merchants, beneficial owners, authorized personnel, and counterparty wallet addresses (where technically feasible) against:
- OFAC Specially Designated Nationals (SDN) and related lists.
- United Nations Security Council Consolidated List.
- European Union consolidated financial sanctions list.
- HM Treasury (United Kingdom) financial sanctions list.
- Other sanctions lists as applicable.
Sanctions screening — enforcement
Screening is performed at onboarding and on an ongoing basis. Matches result in immediate restriction of access pending review and, where confirmed, termination of the relationship and reporting to appropriate authorities.
Halfin does not provide Services to any person or entity subject to comprehensive sanctions or located in jurisdictions listed in the Restricted Countries policy.
Wallet address screening
Where technically feasible and consistent with our non-custodial architecture, Halfin screens cryptocurrency wallet addresses involved in transactions against blockchain analytics indicators of illicit activity, including but not limited to:
- Direct or indirect exposure to sanctioned addresses.
- Connection to known darknet markets, mixers, or fraud schemes.
- Exposure to ransomware payments.
- Other high-risk attribution.
Wallet screening outcomes
Transactions involving high-risk addresses may be flagged, delayed, or rejected pending review.
Suspicious activity reporting
Halfin reports suspicious activity to financial intelligence units, law enforcement, and other competent authorities in accordance with applicable law.
Halfin is not obligated to disclose to a Merchant whether a report has been filed about activity involving that Merchant. "Tipping off" a Merchant about a filed report is prohibited where applicable law requires confidentiality.
Recordkeeping
Halfin retains KYB documentation, transaction records, monitoring outputs, and related records for at least five (5) years following the end of the business relationship or completion of the transaction, or longer where required by applicable law.
Restricted countries and activities
Halfin does not establish business relationships with, or provide Services to, persons or entities located in, incorporated in, or ordinarily resident in jurisdictions listed in the Restricted Countries policy.
Halfin does not provide Services for, and prohibits use of the Services in connection with, any activity listed in the Restricted Activities policy.
Both policies form an integral part of these AML controls and are updated based on changes in applicable law, official advisories, and internal risk assessment.
Cooperation with authorities
Halfin cooperates with lawful requests from regulators, law enforcement, financial intelligence units, courts, and other competent authorities. Such cooperation may include disclosure of personal data and transaction records, subject to applicable legal protections.
Training
Halfin personnel involved in AML-related functions receive periodic training on this Policy, applicable regulations, and emerging risks. Training is recorded and reviewed.
Governance
Halfin has appointed a compliance function responsible for the development, maintenance, and oversight of this Policy. The compliance function operates independently of commercial functions and has direct reporting access to senior management.
The Policy is reviewed at least annually and updated to reflect changes in applicable law, sanctions, regulatory expectations, and Halfin's risk profile.
Merchant obligations
Merchants must:
- Provide accurate, complete, and current KYB and ongoing compliance information.
- Maintain their own AML controls consistent with the requirements of their jurisdiction and business.
- Not use the Services in connection with money laundering, terrorism financing, sanctions evasion, fraud, or any other activity listed in the Restricted Activities policy.
- Cooperate with reasonable requests for information and documentation.
- Notify Halfin promptly of any change in their compliance status or relevant regulatory developments.
- Comply with all applicable laws in the jurisdictions in which they operate.
Consequences of non-compliance
Failure to comply may result in suspension or termination of access, reporting to authorities, and other measures consistent with applicable law.
Updates to this Policy
Halfin may update this Policy from time to time. Material changes will be notified through the Website, by email, or through the dashboard. Continued use of the Services after changes take effect constitutes acceptance.