How SouthPay screens merchants, monitors transactions, complies with sanctions, and cooperates with regulators. This statement is a public summary of the binding SouthPay AML Policy.
SouthPay is a software and payment orchestration platform operated by SouthPay LLC, a Wyoming limited liability company ("SouthPay"). SouthPay enables merchants to accept cryptocurrency payments through integrations with regulated third-party payment service providers ("PSPs").
We are committed to operating SouthPay in a manner that protects the integrity of the financial system and that prevents the platform from being used to facilitate money laundering, terrorist financing, sanctions evasion, fraud, or other financial crime. This statement summarizes the principal commitments and controls that apply to merchants and transactions on SouthPay.
Governing policy. This statement is a summary intended for merchants and the public. The full and binding policy is the SouthPay LLC Anti-Money Laundering, Counter-Terrorist Financing, and Sanctions Compliance Policy (the "SouthPay AML Policy"), available from SouthPay on request. In the event of any inconsistency between this statement and the SouthPay AML Policy, the SouthPay AML Policy prevails.
SouthPay does not take custody of merchant or end-user funds at any point. Each payment link issued through SouthPay is associated with a deposit address provisioned by a regulated infrastructure provider. Funds received are routed directly to the merchant's designated payout destination, whether a fiat bank account or a crypto wallet specified by the merchant.
Regulated payment, custody, settlement, fiat conversion, and related financial services are performed exclusively by our PSPs, each of which operates under its own license, registration, or regulatory authorization, and each of which conducts its own customer due diligence and Financial Crime program. SouthPay is the orchestration layer between the merchant, the payer, and the PSP.
We onboard merchants in coordination with the applicable PSP. Depending on the service track and the PSP, merchants are subject to know-your-business ("KYB") procedures that may include verification of:
Where a merchant's circumstances present elevated risk, including the involvement of a politically exposed person, exposure to a high-risk jurisdiction, or operation in a higher-risk industry, we apply enhanced due diligence before onboarding is finalized. Merchants are required to provide accurate and complete information and to update us promptly when their circumstances change.
Crypto-to-crypto track. KYB requirements for the crypto-to-crypto track are determined by the applicable PSP and applicable law. Even where formal KYB is not required by a PSP, merchants remain subject to sanctions screening, prohibited-relationship rules, and ongoing monitoring as described in this statement.
Crypto-to-fiat track. KYB is mandatory for the crypto-to-fiat track. Merchants who do not satisfy KYB requirements will not be onboarded, and existing merchants who fail ongoing KYB obligations may have their access to settlement suspended or terminated.
We screen merchants, their principals and beneficial owners, and payout destinations against international sanctions lists, including those administered by OFAC, the United Nations Security Council, the European Union, and HM Treasury, and against blockchain analytics designations of sanctioned digital asset addresses. Screening is performed at onboarding and on an ongoing basis as lists are updated.
We do not onboard or transact with persons or entities subject to applicable sanctions, and we do not facilitate transactions associated with comprehensively sanctioned jurisdictions, including (without limitation) North Korea, Iran, Cuba, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine. Additional jurisdictions may be subject to enhanced restrictions or exclusion based on sanctions designations, regulatory risk, FATF identifications, or PSP requirements. The full classification is set out in the SouthPay AML Policy, which is updated from time to time.
Confirmed sanctions hits are blocked or rejected and reported to relevant authorities as required.
Transactions on SouthPay are subject to layered monitoring designed to detect activity that is unusual, inconsistent with the merchant's established profile, or otherwise suggestive of Financial Crime.
Where activity is escalated as suspicious, we report to relevant authorities as required by applicable law and coordinate with the applicable PSP. We do not disclose to merchants or third parties whether a report has been or may be filed, except as expressly permitted by law.
Merchants may not use SouthPay, and we will refuse, suspend, or terminate access where SouthPay is used or proposed to be used:
We cooperate with lawful requests from competent authorities, law enforcement, and our PSPs in accordance with applicable law. Subpoenas, court orders, and equivalent regulatory inquiries should be directed to the contact below.
We retain records relating to merchant onboarding, transactions, sanctions screening, and compliance decisions for not less than five (5) years from the date of the relevant activity or the end of the merchant relationship, whichever is later, or for such longer period as may be required by applicable law.
We may update this statement from time to time without prior notice. The version published on the SouthPay website at any given time is the version then in force. Continued use of SouthPay after an update constitutes acceptance of the updated statement.
Questions and reports relating to this statement may be directed to: