Anti-Money Laundering Policy: scope and duties
This policy explains PIKABAO's requirements for identity checks, transaction monitoring, unusual-activity handling, record retention and cooperation with lawful inquiries. These measures apply to card issuance, top-ups, card use and refunds.
1. Stance and Scope of Application
This Anti-Money Laundering Policy is established and enforced by Pikabo Technology Co., LIMITED, and applies to all accounts using the PIKABAO Virtual Cards service. Virtual cards are issued through licensed upstream card issuers, and the issuers and payment processors also bear their own anti-money-laundering obligations. The aim of the rules is to make the source and use of funds explainable; normal use is not affected.
2. Customer Identification and List Screening
- When applying for a card, you fill in your name, ID number and basic details, which serve as the basis for customer identification.
- The platform does not require you to upload a photo of your ID, nor does it require facial recognition; identification relies mainly on the information you fill in and follow-up checks.
- When the same identity information is used to register multiple accounts, the accounts involved will be restricted.
- When cards are issued and funds are operated, the platform runs list comparisons on names and ID information, including sanctions lists, terrorist-financing-related lists and publicly known high-risk lists.
3. Abnormal Transaction Monitoring
Transaction patterns that draw attention
| Monitored pattern | What is watched |
|---|---|
| A single transaction or daily cumulative amount noticeably larger than usual | Whether it matches the account's historical usage scale |
| Multiple small operations within a short time | Whether there are signs of amount splitting |
| Topped up but unused for a long time, then refunded in a concentrated manner | Whether the funds may be used for passing through |
| Cards used predominantly at merchants in restricted categories | Whether prohibited uses are touched |
| A clear change in login location, or multiple accounts operated from the same network | Whether the account is used by others or linked to other accounts |
Triggering attention is not a finding of violation; in most cases it only requires additional explanation. The review dimensions include amount, frequency, time distribution, the account's historical behavior and merchant categories.
4. Risk Tiering and Enhanced Review
Risk tiers and the corresponding handling
- Standard review: routine use; simply follow the on-page prompts.
- Enhanced review: when a relatively large amount is involved, when money in and out does not match the stated purpose, or when a list hit requires re-verification, you will be asked to explain the source and use of the funds and to provide verifiable supporting documents.
- Restricted status: while a review is pending, card issuance, balance transfers and refunds may be suspended.
5. Prohibited Uses
Cash-out, paying or collecting on behalf of others, using another person's identity information, and transactions involving illegal or restricted categories all count as prohibited uses. The complete list and the consequences of violation are in Chapter 4 of the Terms of Service.
6. Handling and Reporting of Suspicious Transactions
Handling order
- Restrict fund operations on the cards and accounts involved to prevent the risk from spreading.
- Ask the account holder to explain the source and use of the funds and to submit verifiable supporting documents.
- If the review passes, normal use is restored; if it does not, the service is terminated in accordance with the rules.
- Where reporting is required by law, the competent authorities are notified in accordance with the applicable law and regulatory requirements.
7. Cooperation with Competent Authorities and Internal Compliance
When the platform receives an investigation or assistance request lawfully issued by a competent authority, it verifies the legality and scope of the request, and provides the necessary account and transaction records within that scope; the review process is documented. The platform does not provide account information on the basis of informal verbal requests. Customer service, operations and engineering staff receive annual anti-money-laundering and counter-terrorist-financing training, and sensitive operations are logged and traceable. The rules are updated in line with regulatory requirements and upstream issuer rules.
8. Reporting Suspicious Behavior
If you notice someone using virtual cards for suspicious activity, or someone soliciting your account credentials in the name of the platform, you can report it through the Help Center, and the platform will keep the reporter's information confidential.
Preparing source-of-funds and purpose evidence
When asked for additional information, provide genuine records that corroborate one another. A review is not a finding of violation; outcomes and restricted actions follow notices and applicable rules.
Source of funds
Explain ownership and provide transfer records or lawful-source evidence when officially requested. Match amounts, dates and account details; do not substitute another person’s records.
Spending purpose
Identify the merchant, product or service, order number and actual purpose. Record spending, merchant refunds and withdrawals separately; do not disguise fund transfers as purchases.
Sensitive evidence
Provide required fields and redact irrelevant data. Do not send passwords, codes, full card numbers, CVV, private keys or seed phrases; confirm unclear requests officially.
Records and follow-up during review
This evidence guidance does not change policy duties concerning review, restrictions, retention or cooperation with authorities.
Record the restriction
Keep the notice, time and unavailable actions. Distinguish account restrictions from card freezes; do not bypass restrictions by funding or replacing cards.
Provide evidence together
Submit purpose explanations and evidence requested in the original ticket. Keep facts consistent and identify corrections explicitly.
Follow the outcome
Removal, further investigation or termination follows the review outcome. Fund returns still require refund-policy and legal conditions; verbal assurances do not replace notices.
Frequently Asked Questions
Is identity verification required to open a card?
Yes. You need to fill in your name, ID number and basic details, and a list comparison is performed. The platform does not require you to upload a photo of your ID, nor does it require facial recognition.
Why is my account restricted?
There are three common reasons: the transaction scale does not match the account's history, the purpose of the funds needs to be explained, or a list hit requires manual re-verification.
What should I provide when asked to explain the source of funds?
Materials that corroborate each other work best, such as lawful proof of the source of funds and a statement of the intended use.
Can a refund be delayed by a compliance review?
Yes. While a review is pending, refunds may be suspended, and they are restored once it is confirmed that no further review is needed.
Will normal cross-border purchases be treated as abnormal?
No. What draws attention is mostly amounts, frequencies or merchant categories that clearly do not match the account's history.
What if I find someone using virtual cards for suspicious activity?
Report it through the on-site help channels, and the platform will keep the reporter's information confidential.