AML policy

KeyFusion Global F.Z.E operates KeyFusion, a shop selling digital gift cards, game keys and software licences. It is registered in Ajman Free Zone, United Arab Emirates and is bound by the anti-money-laundering and counter-terrorist-financing laws that apply there, as well as by the rules of the payment processors it depends on.

This page sets out what we do to keep this shop from being used to move criminal proceeds, and what we will refuse. It is written to be checked: the figures below are the ones the checkout actually enforces.

The design does most of the work

The usual way a digital shop is abused is as a rinse — value goes in dirty and comes back out clean somewhere else. That is not possible here, and not because we watch for it:

• There is no way to take money out. Balance can be spent on goods in this catalogue and on nothing else. There is no withdrawal, no transfer to another account, and no payment to a bank or wallet address. Refunds, cancellations and referral rewards are all credited back to the same balance rather than sent anywhere.
• Nothing is bearer property. What is delivered is a code tied to a brand, a region and a face value, issued to the account that bought it. It is worth less than it cost to almost anyone else, which is the opposite of what a launderer needs.
• Every payment is traceable to a chain. Funding is cryptocurrency (via NOWPayments). Each deposit carries an address, a transaction hash and a timestamp, and those are kept with the order.

This is stated first because it is the honest reason the risk here is low. The controls below exist to cover what the design does not.

What we will not accept

• Payment by anyone other than the account holder. The person funding a balance must be the person spending it. We do not accept payment on behalf of a third party, and an account that appears to be funded by others will be suspended.
• Cash, or any payment method we have not published. We accept the coins listed in the footer of this site and nothing else. Any offer to pay by another route is refused without exception.
• Buying on behalf of an undisclosed principal.If you are buying for a business, the account must be in that business’s name.
• Reselling into a market you have concealed from us. Volume purchasing is welcome and is what this shop is for; concealing who the end buyer is when we ask is not.
• Any account we believe is not being operated by its owner. Sharing an account, selling one, or operating one on someone else’s instructions ends it.
• Structuring. Splitting a purchase into smaller ones, or across several accounts, to stay under a threshold on this page is treated as the single larger transaction it is, and as grounds for suspension in its own right.

Who we will not deal with

We will not knowingly open an account for, sell to, or hold a balance for any person or entity that is subject to financial sanctions, is acting for someone who is, or is resident in a jurisdiction we are prohibited from dealing with. Where we become aware that an existing account meets any of those descriptions, we will suspend it and freeze the balance rather than refund it, and we will act on the instructions of the competent authority.

You are responsible for telling us the truth about who you are. Opening an account is a statement that you are not any of the above.

Verification we ask for

Buying small amounts needs an account and nothing more. Verification is asked for as the amounts rise, and at the following points:

• $50 on a single order, or $100 across the last 24 hours, asks for proof that the person placing the order is the account holder, using the sign-in method on the account.
• An identity check may be required before any order is released, at any amount, where we have a reason to make one. We will say what we need and why.
• Source of funds may be asked for where the size or pattern of deposits does not match the buying on the account.

These are minimums, not allowances. Nothing on this page entitles anyone to buy up to a threshold, and we can ask for more at any point.

What we watch for

Orders, deposits and balance movements are reviewed against the account they belong to. The patterns that get an order held are the ordinary ones: deposits that do not match what is being bought, a sudden change in size or tempo, several accounts sharing an identifier or a payment source, purchases immediately after a change to the sign-in method, and any attempt to reverse or re-route a payment that has already settled.

A held order is not an accusation and is usually resolved the same day. Delivery can be suspended at the platform level while a review runs, and the balance stays where it is in the meantime.

Reporting

Where we know or suspect that funds are the proceeds of crime, or are intended for terrorist financing, we will report it to the competent authority in the United Arab Emirates. We will do so whether or not the transaction went through, and whether or not the account is still open.

We will not tell you that a report has been made. Disclosing it is itself an offence, so if an account is closed or an order refused without an explanation, no explanation should be inferred from the silence.

Records

Account details, order history, delivered codes, balance movements and deposit references are kept for at least five years after the last activity on an account, and longer where an authority requires it. That retention takes precedence over a request for deletion — see the Privacy & Cookies Policy, which sets out what is held and what can be asked for.

Refusal, suspension and forfeiture

We may refuse an order, suspend an account, or hold a balance where this policy requires it, and we do not have to say which of these applies. Where an account is closed for a reason other than a suspicion we are barred from disclosing, a remaining balance is refunded to the source it was funded from. Where we are barred from disclosing, or where an authority has directed otherwise, it is not.

Using this shop is agreement to that. It is the term most likely to matter to anyone reading this page in good faith, so it is written plainly rather than buried in the Terms & Conditions.

Responsibility and contact

KeyFusion Global F.Z.E is responsible for this policy and reviews it at least annually. Questions, and anything you think we ought to know about an account, go to info@keyfusion.io or to @KeyFusion on Telegram.

B.C. 1304659 – C1 Building, Ajman Free Zone, UAE