Legal & Compliance

KYC & AML Compliance Policy

Our comprehensive Know Your Customer, Anti-Money Laundering, and Counter-Terrorist Financing procedures.

Last updated: October 16, 2026

1. Regulatory Commitment & Objectives

AtlasKeys is committed to the highest standards of international regulatory compliance, integrity, and corporate ethics. We strictly prohibit our platform from being used for money laundering, terrorist financing, fraud, credit card cracking, or the commercial fencing of illicitly acquired digital goods.

Our compliance framework is designed in strict accordance with the Financial Action Task Force (FATF) Recommendations, European Union 5th and 6th Anti-Money Laundering Directives (AMLD5/AMLD6), and applicable national regulations governing money services businesses and digital marketplaces.

2. Customer Due Diligence (CDD) Verification Tiers

We apply a risk-based Customer Due Diligence (CDD) framework. Account capabilities and withdrawal ceilings scale with the user's verified identity tier:

Tier Level Prerequisites Thresholds & Capabilities
Tier 0
(Basic Buyer)
Verified Email, Phone SMS verification, and risk-cleared payment gateway device telemetry. Purchases up to $500 lifetime. Escrow buyer protection active. Withdrawals and key sales strictly prohibited.
Tier 1
(Verified Buyer / Casual Seller)
Tier 0 + Valid government-issued photo ID (passport, national ID, driver's license) + automated 3D biometric selfie liveness check. Purchases up to $5,000 monthly. Seller payouts permitted up to $1,000 monthly via verified withdrawal channels.
Tier 2
(Verified Merchant)
Tier 1 + Certified Proof of Residential Address (dated within last 90 days) + verified payout source (SEPA / Bank statement or corporate crypto wallet). Purchases unlimited. Merchant listing and withdrawal capacity up to $25,000 monthly.
Tier 3
(Enterprise Power Merchant)
Tier 2 + Enhanced Due Diligence (EDD), Certificate of Corporate Incorporation, Ultimate Beneficial Owner (UBO >25%) verification, and supplier invoice trail audits. Unlimited marketplace listing volume, custom payout rails, dedicated merchant support account executive.

3. Required Documentation & Validation Standards

When an account reaches a tier threshold or triggers an algorithmic risk review, the following evidentiary standards are enforced:

  • Government-Issued Photo ID: Must be an unexpired, original color document containing the user's full legal name, date of birth, photo, unique document number, and Machine Readable Zone (MRZ) where applicable (e.g., international passport, national identification card, or photocard driver's license). Screenshots, black-and-white photocopies, and expired credentials are categorically rejected.
  • Biometric Liveness Match: Users complete a real-time, interactive camera facial scan to confirm physical presence and detect digital deepfakes, masks, or synthetic identity manipulation.
  • Proof of Address: A utility bill (water, gas, electricity), municipal property tax statement, or bank statement issued in the applicant's name with an issue date within the last ninety (90) calendar days. Mobile phone bills and P.O. Box addresses are not accepted.
  • Corporate Entities: Registered commercial sellers must provide an official Certificate of Good Standing, Articles of Association, Tax Identification Number (TIN/VAT), and passport copies for all directors and major shareholders.

4. Transaction Monitoring & PEP Screening

Our compliance operations utilize real-time automated telemetry and machine-learning risk engines to detect unlawful conduct:

  • Structuring & Smurfing Detection: Algorithms monitor for split transactions executed just below verification thresholds designed to bypass automated KYC prompts.
  • Velocity & Geolocation Flags: Immediate scrutiny is applied to sudden transaction spikes, rapid wallet withdrawals within minutes of order completion, or logins routed through known TOR exit nodes and high-risk proxies.
  • Sanctions & PEP Screening: All account holders and corporate officers are screened continuously against global sanctions registers, including the United States Office of Foreign Assets Control (OFAC), the European Union Consolidated Financial Sanctions List, HM Treasury (UK), and the United Nations Security Council (UNSC) Consolidated List, as well as Politically Exposed Persons (PEP) watchlists.

5. Suspicious Activity (SAR) & Asset Freezing

Where transactions exhibit indicators of criminal conduct, fraud, or terrorist affiliation:

  • AtlasKeys reserves the unilateral right to immediately freeze affected user accounts, suspend active digital key listings, and place an administrative hold on all pending escrow balances.
  • Our certified Anti-Money Laundering Officers file formal Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) with appropriate national Financial Intelligence Units (FIUs).
  • Anti-Tipping-Off Mandate: In accordance with statutory AML provisions, AtlasKeys compliance personnel are legally prohibited from disclosing to the account holder that a SAR or regulatory investigation has been submitted.

6. Data Protection & Retention

All sensitive identity documents uploaded during the verification workflow are stored in isolated, air-gapped storage buckets encrypted with AES-256 cipher suites. Access is restricted exclusively to vetted compliance auditors and encrypted API channels connected to accredited identity-verification partners.

Under statutory international anti-money laundering mandates, customer identification documents and transaction logs must be retained for a minimum period of five (5) years following the termination of the customer relationship, after which records are permanently expunged.

7. Compliance Office Contact

For inquiries regarding identity verification status, enterprise seller onboarding, or legal enforcement requests, reach out directly to our compliance officers:

AtlasKeys Compliance & Regulatory Affairs Bureau
AML Operations: compliance@atlaskeys.com
Identity Verification Desk: kyc@atlaskeys.com
Corporate Merchant Desk: merchants@atlaskeys.com