This Anti-Money Laundering (AML) Policy explains how RevealMe ("we", "us", "our") helps prevent money laundering, terrorist financing, and other illicit financial activity on our platform. It applies to all users, including content creators and account holders who earn from the platform ("Sellers") and users who purchase, tip, or otherwise transact ("Fans"). By using RevealMe, you agree to comply with this AML Policy in addition to our Terms of Use and Privacy Policy.

1. Purpose & Scope
We operate a risk-based compliance program designed to detect, deter, and report suspicious activity. This Policy covers:
•	User onboarding and verification (KYC/KYB)  
•	Payments, tips, and withdrawals  
•	Ongoing monitoring and screening (including PEP/sanctions)  
•	Record keeping, reporting, and non-tipping off  
•	Training, governance, and enforcement

2. Definitions
•	"Money Laundering": Activities intended to conceal the origin of criminal proceeds.  
•	"Terrorist Financing": Provision or collection of funds intended to support terrorism.  
•	"PEP": Politically Exposed Person, including close associates and family members.  
•	"Sanctions": Restrictions issued by governments or international bodies prohibiting certain activities with specified persons or jurisdictions.

3. User Categories and Verification
We may apply different verification standards based on user role, actions, and risk.
•	Sellers (required for earning or withdrawing): We may collect and verify government ID, facial/biometric checks (where lawful), date of birth, address, payment account ownership, and (where appropriate) source of funds/wealth.  
•	Fans: For payment use and where risk indicators arise, we may require ID verification or additional information.  
•	Businesses/Agencies: Where applicable, we may verify legal entity information and beneficial owners.

If satisfactory verification is not completed or risk is excessive, we may refuse, restrict, suspend, or terminate access.

4. Risk-Based Approach & Enhanced Due Diligence (EDD)
We assess risks considering factors like transaction patterns, payment methods, jurisdictions, customer type, and adverse media. Where higher risk is identified, we apply EDD, which may include:
•	Collecting additional identity, ownership, or source-of-funds/wealth information  
•	Requesting supporting documents (e.g., bank statements, contracts, invoices)  
•	Delaying or limiting features, funds availability, or withdrawals  
•	More frequent reviews and monitoring

5. Sanctions, PEP & Adverse Media Screening
We screen users and relevant counterparties against sanctions lists and may screen for PEP status and adverse media. We do not allow access to the platform where prohibited by applicable sanctions or where risk is unacceptable. We may suspend, block, or close accounts and freeze related activity where required or appropriate.

6. Payments, Tips & Withdrawals
•	We use regulated third-party payment processors and payout providers where possible. By transacting, you also agree to their terms and checks.  
•	We may place limits, hold periods, or rolling reserves on balances and withdrawals for risk control.  
•	We may request proof of ownership for payout accounts (e.g., name match, statements).  
•	Attempts to process payments or payouts that are fraudulent, unauthorized, or designed to obscure funds origin are prohibited.

7. Prohibited & High-Risk Activity (Illustrative)
The following are strictly prohibited and may lead to immediate action:  
•	Using stolen payment cards, compromised accounts, or synthetic identities  
•	Purchase/refund/tip loops or circular flows designed to inflate revenues or cash out illicit funds  
•	Coordinated activity between Sellers and Fans to simulate legitimate commerce  
•	Acting as or using a "money mule" (moving funds on behalf of others without clear lawful purpose)  
•	Transacting on behalf of sanctioned persons, or routing via prohibited jurisdictions  
•	Structuring transactions to evade thresholds, verification, or monitoring  
•	Use of third-party or anonymous wallets/accounts to disguise ownership of funds  
•	Selling or purchasing content/services as a mere pretext to move funds

This list is not exhaustive. See Terms of Use for additional prohibited uses.

8. Monitoring & Red Flags
We use a combination of automated tools and human review to identify unusual or suspicious patterns. Examples of red flags include:
•	Sudden spikes in tips/purchases from limited sources or linked accounts  
•	Repeated chargebacks, refunds, or payment failures  
•	Mismatches between user profile and transaction behavior (e.g., geography, device, IP)  
•	Multiple accounts controlled by the same person to route funds  
•	Using third parties’ cards, wallets, or bank accounts without clear, lawful basis  
•	Attempts to bypass verification, limits, or holds

Where warranted, we may pause transactions or withdrawals, request more information, or take other appropriate measures.

9. Reporting & Non-Tipping Off
We may be legally obligated to report suspicious activity to competent authorities. You acknowledge we may share relevant information without notice where required.  
Non-tipping off: If we are investigating or reporting suspicious activity, we may be prohibited from informing you. Do not request or encourage disclosure of any reporting decisions.

10. Record Keeping
We retain AML-relevant records (including identification data, transaction data, communications, risk assessments, and reports) for as long as required by applicable law and, in any event, no less than five (5) years after the end of the relationship or the relevant transaction, unless a longer period is required or permitted.

11. Third-Party Providers
We may rely on regulated third parties for payments, payouts, screening, verification, analytics, or storage. Their terms, privacy practices, and lawful requests may apply in addition to ours.

12. Training, Governance & Reviews
We maintain an internal AML compliance program with designated responsibility for oversight. Relevant staff receive periodic AML training. Our controls, tools, and procedures are reviewed and updated periodically based on risk, legal developments, and platform changes.

13. Consequences of Breach
Violations of this AML Policy or our Terms of Use may result in:  
•	Suspension or termination of access or features  
•	Blocking or reversing transactions, freezing balances, or cancelling withdrawals  
•	Reporting to payment partners, financial institutions, or authorities  
•	Civil or criminal legal action, where applicable

14. How to Report Concerns
If you believe activity on the platform may be suspicious or in breach of this Policy, please contact us via our Contact page. Provide relevant details (e.g., profile URLs, transaction references, timestamps). Do not investigate on your own or alert other users about your concerns.

15. Updates to this Policy
We may update this AML Policy from time to time. Material changes will be posted on this page and may be referenced in our Terms of Use. Continued use of the platform after changes are posted constitutes acceptance of the updated Policy.