AML & KYC Policy

This Policy applies to every user who buys, sells, or holds a payout balance on StarPlace, and to every transaction processed through our payment processor (PayPal). StarPlace and PayPal apply complementary controls; obligations under PayPal's Acceptable Use Policy and User Agreement apply in addition to this Policy.

We apply a risk-based approach. All users must accept our Terms and confirm they are at least 18 years old. Additional verification is required at the following points:

• Seller onboarding: government-issued ID, selfie liveness check, and proof of address before the first payout is released.
• Cumulative buyer activity: ID verification once a buyer's lifetime spend exceeds USD 1,000.
• Single high-value order: ID verification for any single order at or above USD 1,000.
• Cumulative seller activity: enhanced documentation once a seller's annual gross volume exceeds USD 5,000, and tax-residency self-certification (W-8/W-9 equivalents) where required by the jurisdiction.
• Risk triggers: mismatched country/IP, multiple cards, sudden volume changes, prior chargebacks, or any pattern flagged by our or PayPal's fraud systems.

EDD is applied when:

• the user is a Politically Exposed Person (PEP), a close associate, or family member;
• the user is resident in, or transactions are routed through, a jurisdiction listed by FATF as high-risk or under increased monitoring, or sanctioned under UN / OFAC / EU / UK measures;
• monthly volume exceeds USD 10,000 or its equivalent;
• a transaction has no reasonable economic rationale or appears structured to avoid thresholds.

EDD may include source-of-funds questions, additional documentation, and senior-staff sign-off before activity is allowed to continue.

We screen users at onboarding and on an ongoing basis against, at minimum: the UN Consolidated Sanctions List, the OFAC SDN list, the EU consolidated list, and the UK HM Treasury list. Matches are reviewed manually before any account action is taken. We will not knowingly do business with sanctioned individuals or entities, regardless of our processor's controls.

Automated rules monitor every order for indicators such as: rapid sequences of similar orders, transactions just below verification thresholds, mismatched delivery emails, chargeback history, device sharing across accounts, and known-fraud patterns. Flagged activity is reviewed by a human analyst.

Where we have reasonable grounds to suspect money laundering, terrorism financing, or other illicit activity, we will file a report with the competent authority and may freeze the relevant account and funds for the duration of the investigation. We will not tip off the subject of a report. Competent authorities include, among others:

• Brazil: Council for Financial Activities Control (COAF), under the Federal Revenue Service.
• European Union: the Financial Intelligence Unit of the relevant Member State (e.g., TRACFIN in France, FIU-NL in the Netherlands).
• United Kingdom: the National Crime Agency (UKFIU).
• United States: the Financial Crimes Enforcement Network (FinCEN).
• Australia: AUSTRAC.
• Other jurisdictions: the equivalent national financial-intelligence unit.

We retain identification documents, transaction records, and the rationale for any AML decision for at least 5 years from the end of the business relationship or the date of the transaction, whichever is later. Records are stored encrypted and access is limited to staff with a documented need.

We may refuse to onboard a user, decline a transaction, freeze a payout, or terminate an account at any time if we believe doing so is necessary to comply with this Policy, applicable law, sanctions, or the requirements of our payment processor. Where lawful and not a tipping-off risk, we will communicate the reason and offer a procedure to respond. We will not be liable for losses caused by such actions taken in good faith.

Staff with access to AML decisions receive periodic training on red flags, sanctions, and reporting obligations. The DPO and the AML Officer (contact channels on the Operator Identification page) are responsible for this Policy and review it at least annually.

We cooperate with lawful requests from regulators, law-enforcement and tax authorities in any jurisdiction where we have a legal obligation to do so. We may produce records, freeze accounts, or block transactions as legally required.

AML questions or to flag a concern: contact@starplace.net.