KYC & AML Policy
Last update: Jun 27, 2024
Purpose
This KYC & AML Policy outlines the principles and procedures followed by Leading Cards. a technology platform providing access to virtual payment cards for affiliate marketing, online media purchases, and IT services related to media. The purpose of this policy is to prevent misuse of our platform for money laundering, fraud, or other unlawful activities.
Scope
This Policy applies to all Users of the Leading Cards platform. It is designed to meet international standards for anti-money laundering and counter-terrorist financing while remaining appropriate for a technology platform that does not act as a financial institution or directly handle client funds.
Our Role
Leading Cards is ot a bank, not a licensed payment service provider, and does not directly issue cards or hold User funds. All cards available via our platform are issued by authorized third-party providers. Leading Cards functions solely as a technology layer facilitating access to such services.
User Verification (KYC)
Leading Cards verifies the identity of Users before enabling full access to card-related features. Verification may be required based on the User's activity level, location, or risk profile. We reserve the right to request identification at any time.
Minimum KYC Requirements:
For individuals:
  • Full name
  • Email address and phone number
  • Government-issued ID (passport, driver’s license, or national ID)
  • Proof of address (e.g. utility bill or bank statement, max 3 months old)
For businesses
  • Certificate of incorporation
  • Proof of director’s or authorized representative’s ID
  • Proof of address
  • Business purpose and operational overview
Risk-Based Approach
Leading Cards applies a risk-based approach to onboarding and monitoring Users:
  • Low-risk Users may receive limited access with simplified verification
  • High-risk indicators (e.g. high volume, location risk, inconsistent activity) trigger enhanced due diligence.
  • We reserve the right to request additional documents or suspend access pending review.
Prohibited Activities
Users may not use the platform in connection with:
  • Unlawful transactions or jurisdictions under international sanctions
  • Activities involving unlicensed financial services
  • Any transactions that violate applicable AML/CFT laws
  • Administrative or penalty fees in case of Terms breach
Leading Cards also adheres to internal guidelines that exclude usage for:
  • Cryptocurrency exchanges
  • Adult content services
  • Gambling or betting
  • High-risk financial transfers or mixers
A complete list of restricted activities may be updated and maintained internally.
Monitoring & Reporting
  • We monitor platform activity for unusual or suspicious behavior.
  • We conduct internal reviews of flagged transactions or profile changes.
  • We may report suspicious activity to third-party issuing partners or relevant legal authorities, as required by law or contractual obligations.
Leading Cards reserves the right to suspend or terminate a User account if there is reasonable suspicion of unlawful activity.
Data Retention
We retain KYC documentation and relevant user data for a minimum of 5 years following the end of a User’s relationship with Leading Cards, in compliance with international AML standards.
Training & Oversight
Leading Cards ensures internal staff and key personnel are aware of AML compliance requirements and trained to implement this policy responsibly.
A designated Compliance Contact is responsible for:
  • Reviewing high-risk profiles or flagged activity
  • Ensuring procedures are followed
  • Communicating with relevant partners and authorities, where appropriate
Leading Cards may update this policy at any time to reflect changes in business practices or legal requirements. Users are encouraged to periodically review this page. Continued use of the platform constitutes acceptance of the most recent version of this policy.
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