(KYC) Policy
Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy
Last Updated: 01/01/2026
This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the principles, procedures, and controls adopted by TOM TRANSFER to prevent money laundering, terrorist financing, fraud, and other illicit activities.
TOM TRANSFER is committed to maintaining a secure, transparent, and compliant platform in line with internationally recognized compliance standards and risk-based practices.
1. Purpose of This Policy
The purpose of this AML & KYC Policy is to:
Prevent the misuse of the platform for money laundering or financial crime
Establish customer identification and verification standards
Define monitoring and reporting procedures
Ensure compliance with applicable legal and regulatory requirements
Protect the integrity, reputation, and security of the platform
2. Scope
This Policy applies to:
All users of the TOM TRANSFER platform
All services related to virtual card issuance and electronic transactions
All internal operations, employees, contractors, and service providers involved in platform activities
3. Regulatory Approach
TOM TRANSFER adopts a risk-based approach to AML and KYC compliance, taking into account:
Nature of the services provided
Customer type and geographic location
Transaction behavior and usage patterns
Evolving risks related to digital payments
Important Notice:
TOM TRANSFER operates as a financial technology (FinTech) platform and does not represent itself as a bank or licensed financial institution. Compliance measures are implemented proportionately to the nature of the services provided.
4. Customer Due Diligence (CDD)
TOM TRANSFER performs Customer Due Diligence to identify and verify users before granting access to certain services.
4.1 Information Collected
Depending on the risk profile, users may be required to provide:
Full legal name
Date of birth
Nationality
Email address and phone number
Residential address
Government-issued identification documents
5. Know Your Customer (KYC) Procedures
KYC procedures may include:
Identity verification using official documents
Verification of contact details
Review of submitted information for accuracy and consistency
Ongoing verification where necessary
TOM TRANSFER reserves the right to request additional documentation or clarification at any time.
6. Enhanced Due Diligence (EDD)
Enhanced Due Diligence may be applied where higher risk is identified, including but not limited to:
Unusual transaction behavior
High transaction volumes
Users operating in higher-risk jurisdictions
Business or corporate users
EDD measures may include additional identity checks, source-of-funds verification, or transaction limits.
7. Transaction Monitoring
TOM TRANSFER implements transaction monitoring measures to identify potentially suspicious or unusual activities.
Monitoring may include:
Transaction frequency and volume analysis
Detection of abnormal usage patterns
Review of failed or reversed transactions
Internal alerts and reviews
8. Suspicious Activity Reporting
Where suspicious activity is identified, TOM TRANSFER may:
Temporarily restrict or suspend accounts or transactions
Conduct internal reviews and investigations
Report relevant information to appropriate authorities where legally required
Users acknowledge that such actions may be taken without prior notice where permitted by law.
9. Prohibited Activities
The platform must not be used for:
Money laundering or terrorist financing
Fraud, scams, or deceptive practices
Circumventing sanctions or regulatory controls
Any illegal or prohibited activity under applicable law
Violation of these rules may result in immediate account suspension or termination.
10. Record Keeping
TOM TRANSFER maintains records of:
Customer identification and verification data
Transaction histories
Compliance reviews and internal assessments
Records are retained only for as long as necessary to meet legal, regulatory, and operational requirements.
11. Data Protection and Confidentiality
All personal data collected for AML/KYC purposes is handled in accordance with TOM TRANSFER’s Privacy Policy and applicable data protection laws.
Access to such data is restricted to authorized personnel only.
12. Training and Awareness
TOM TRANSFER ensures that personnel involved in compliance-related functions receive appropriate training on:
AML and KYC principles
Risk indicators
Reporting obligations
Data protection responsibilities
13. Third-Party Service Providers
TOM TRANSFER may rely on trusted third-party service providers to support identity verification or transaction monitoring.
Such providers are selected based on confidentiality, security, and professional standards.
14. Policy Review and Updates
This AML & KYC Policy is reviewed periodically and updated as necessary to reflect:
Changes in legal or regulatory requirements
Emerging financial crime risks
Operational or technological developments
Updated versions will be published on the website.
15. User Cooperation
By using the TOM TRANSFER platform, users agree to:
Provide accurate and truthful information
Cooperate with verification and compliance requests
Notify TOM TRANSFER of any changes to their information
Failure to cooperate may result in service restrictions or termination.
16. Governing Principles
This Policy is guided by internationally recognized AML and KYC best practices, including risk-based compliance frameworks commonly adopted within the financial technology sector.
17. Contact Information
For questions regarding this AML & KYC Policy, please contact:
Email: contact@tomtimes.center
Location: Canada
Final Statement
By accessing or using the TOM TRANSFER platform, you acknowledge and accept the AML & KYC requirements outlined in this Policy as a condition of service usage.