Blind Pay, Inc. ("Blind Pay") is committed to preventing the misuse of its products and services for money laundering, terrorist financing, sanctions evasion, fraud, or other financial crimes. We maintain a robust, risk-based compliance program designed to meet or exceed applicable regulatory expectations across the jurisdictions in which we operate.
Blind Pay is registered as a Money Services Business (MSB) with the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) and operates in coordination with licensed financial-institution partners globally. Our compliance framework is aligned with the Bank Secrecy Act (BSA), U.S. sanctions regulations administered by the Office of Foreign Assets Control (OFAC), Financial Action Task Force (FATF) recommendations, and applicable local regulatory requirements.
Blind Pay applies a zero-tolerance approach to financial crime. We do not knowingly facilitate or support money laundering, terrorist financing, sanctions violations, or illicit activity of any kind. This commitment applies to all customers, counterparties, transactions, products, employees, and partners.
Blind Pay maintains a comprehensive, risk-based Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) program that includes:
We identify and verify customers and beneficial owners prior to establishing a business relationship, applying enhanced due diligence where higher risk is identified.
Customers are risk-rated based on factors including geography, business activity, transaction behavior, and ownership structure, and are subject to ongoing review throughout the relationship.
Blind Pay screens customers, beneficial owners, and relevant counterparties against applicable sanctions lists, politically exposed person (PEP) databases, and adverse media sources at onboarding and on an ongoing basis.
Transactions are monitored to detect unusual or suspicious activity that may indicate financial crime, including activity inconsistent with a customer's known profile or business purpose.
Where required, Blind Pay files Suspicious Activity Reports (SARs) with FinCEN and cooperates fully with law enforcement and regulatory authorities, while maintaining strict confidentiality and non-tipping-off obligations.
Blind Pay does not onboard or support customers, jurisdictions, or business models that fall outside of its defined risk appetite, including sanctioned entities, prohibited countries, and high-risk or illicit activities.
Blind Pay's compliance program is overseen by senior management and the designated Compliance Officer, who is responsible for the design, implementation, and ongoing effectiveness of the AML and sanctions framework. The program is reviewed regularly and updated to reflect regulatory developments, emerging risks, and changes in business activity.
Independent testing, internal controls, and periodic audits are conducted to assess program effectiveness and ensure continuous improvement.
All employees receive regular training on AML, sanctions, and financial-crime risk appropriate to their roles. Blind Pay promotes a strong culture of compliance, accountability, and ethical conduct across the organization.
Blind Pay cooperates fully with regulators, law enforcement agencies, and partner financial institutions in the prevention, detection, and investigation of financial crime, in accordance with applicable laws and data-protection requirements.
This AML Policy Statement is provided for informational purposes and reflects Blind Pay's commitment to maintaining a strong, risk-based financial crime compliance program. It does not replace or supersede internal policies, procedures, or regulatory obligations.