This policy describes the approach of the vircard.io service — operated by __operator details__ (hereinafter “we”, the “service”, “Vircard”) — to combating the laundering of proceeds of crime and the financing of terrorism, as well as to compliance with sanctions restrictions.
Vircard is a technology service that provides access to the issuance of virtual payment cards through a partner payment infrastructure. Cards are issued by a licensed issuer; Vircard is not a bank and does not accept deposits.
Version dated September 1, 2026.
1. Purpose of the Policy
The policy sets out the rules by which we onboard customers, verify them, and monitor transactions so that the service is not used for laundering criminal proceeds, financing terrorism, or circumventing sanctions restrictions. The policy is binding on the service’s employees and contractors and supplements the Terms of Use.
2. Who Performs the Checks
Checks are performed at two levels: the service verifies the user and their transactions on its own side, while the licensed issuer and the partner’s payment infrastructure apply their own procedures in accordance with their licensing requirements and the rules of the payment systems. The issuer’s decision to refuse or restrict a transaction is binding on us. The requirements applicable to the service operator as an obliged entity are determined by the legislation of __applicable jurisdiction__.
3. Customer Identification and Verification
Before granting access to card issuance, we establish and verify the user’s identity to the extent required by applicable law and the issuer’s rules.
- Basic information about the user: name, date of birth, country of residence, contact details.
- An identity document and, if necessary, proof of address.
- Confirmation that the user acts on their own behalf and not on behalf of a third party.
- Information on politically exposed person status, if applicable.
The set of documents requested and the verification timelines are determined by the issuer’s requirements and specified in the section __set of documents and verification timelines__. We may request information again if previously provided information is outdated or raises doubts; until the information is confirmed, service may be restricted.
4. Sources of Funds and Cryptocurrency Transactions
We may request information about the origin of the funds used to top up the balance, and supporting documents. Top-ups from sources whose origin is not confirmed may be rejected.
Additional checks apply to cryptocurrency top-ups: analysis of the address and the transaction chain for links to addresses on restricted lists, mixers, and services that conceal the origin of funds. The procedure for such analysis and the criteria used are determined by the procedures of the verification provider and specified in the section __procedure for checking cryptocurrency transactions__.
5. Transaction Monitoring
Card transactions are monitored on an ongoing basis. Attention is paid to indicators that are atypical of the user’s normal behavior.
- A sharp change in the volume or frequency of transactions without an explainable reason.
- Splitting of payments, apparently aimed at circumventing thresholds or limits.
- Transactions that do not correspond to the stated purpose of using the card.
- Signs of the account being used by a third party or of the card being transferred to another person.
- Transactions with counterparties from high-risk or restricted categories.
If indicators of a suspicious transaction are identified, we may request explanations, suspend the transaction and, if required by applicable law, submit the information to the authorized authority. We may not be entitled to inform the user of such a submission.
6. Sanctions and High-Risk Restrictions
We do not serve persons included in applicable sanctions and other restricted lists, or persons acting on their behalf. Users and transactions are screened against such lists at onboarding and regularly thereafter. The list of applicable sanctions regimes and restricted countries is determined by the issuer’s requirements and specified in the section __list of applicable sanctions regimes and restricted countries__.
7. Prohibited Categories
The service’s cards may not be used for payments in categories prohibited by applicable law, the rules of the payment systems, or the issuer’s requirements.
- Trafficking in narcotic drugs, weapons, and other goods with restricted circulation.
- Materials related to the exploitation of people and other unlawful content.
- Gambling and betting where they are prohibited or require a license that the merchant does not hold.
- Pyramid schemes, fraudulent schemes, cashing out, and sham transactions.
- Circumvention of sanctions restrictions and payments made for the benefit of persons on restricted lists.
8. Suspension and Refusal of Service
We may refuse to open an account, suspend service, or block a card or an individual transaction if the user has failed verification, provided false information, refused to explain a transaction, become subject to restrictive measures, or if the issuer or an authorized authority so requires. The reason for refusal is disclosed to the extent permitted by law.
9. Data Retention
Information and documents obtained during identification, as well as transaction data, are retained for the period established by applicable legislation for obliged entities — __AML document retention period__. The procedure for processing personal data is described in the Privacy Policy.
10. Training and the Responsible Officer
Compliance with this policy is the responsibility of a designated responsible officer — __position and details of the responsible officer__. Employees involved in customer onboarding and transaction processing undergo introductory and periodic training on combating money laundering and complying with sanctions requirements.
11. Policy Updates
The policy is reviewed when applicable requirements, the rules of the payment systems, or the issuer’s procedures change, and also following an internal risk assessment. The current version is published on this page, and the date of the last change is indicated at the top.
12. Contacts
Send questions about this policy and requests from authorized authorities to __address for compliance inquiries__ or to the postal address __operator address__. The operator’s details are __operator details__.