AML / Anti-Fraud Policy

This AML / Anti-Fraud Policy describes the measures OCAI LTD ("HoneyPot," "we," "our," or "us") takes to detect, prevent, and report money laundering, terrorist financing, payment fraud, and other financial misuse of honeypot.com.

1. Commitment

We're committed to operating the Services lawfully and to denying access to anyone attempting to use them for money laundering, terrorist financing, sanctions evasion, payment fraud, or other financial crime. We expect every user and every payment partner to share that commitment.

2. Scope

This Policy applies to all financial transactions on the Services, including:

• Premium subscription purchases
• Credit-recharge purchases
• Any future payouts (e.g. affiliate or creator-program payouts)
• Refunds and chargebacks

3. Know-Your-Customer ("KYC") Practices

While most users transact at low monetary values and don't require formal KYC, we apply risk-based identity checks for:

• Higher-value transactions (above thresholds defined by our payment partners and applicable regulation)
• Transactions flagged by our fraud-prevention systems as anomalous
• Accounts associated with prior fraud, chargebacks, or sanctions matches
• Users in jurisdictions where local law mandates verification at lower thresholds

KYC checks may require government-issued ID, proof of address, source-of-funds documentation, or third-party identity-verification (e.g. biometric checks). We work with established providers and the verification process is bound by our Privacy Policy.

4. Sanctions Screening

We screen users and transactions against applicable sanctions lists, including:

• U.S. Office of Foreign Assets Control ("OFAC") Specially Designated Nationals list
• EU Consolidated Financial Sanctions List
• UK Office of Financial Sanctions Implementation list
• UN Security Council Consolidated Sanctions List
• Equivalent national sanctions lists where required

Matched users are denied access to the Services and the match is reported to relevant authorities as required.

5. Restricted Jurisdictions

We don't knowingly provide the Services to users located in jurisdictions subject to comprehensive sanctions, or to users on any applicable denied-party list. Attempting to access the Services via VPN or other means from a restricted jurisdiction is a violation of our Terms of Service.

6. Transaction Monitoring

We monitor transaction patterns for anomalies that suggest money laundering, fraud, or abuse, including:

• Rapid succession of high-value purchases with new payment instruments
• Purchases followed quickly by chargebacks or refund requests
• Use of multiple payment methods or accounts to circumvent limits
• Account behavior inconsistent with stated location, age, or use pattern
• Use of payment instruments flagged by our processors as high-risk

Flagged transactions trigger a fraud review, which may result in:

• A temporary hold on the affected purchase or balance
• A KYC request
• Account suspension pending verification
• Reversal or refund of the flagged transaction
• Account termination
• A Suspicious Activity Report ("SAR") or equivalent regulatory filing where applicable

7. Payment Partners

We rely on regulated payment partners (Telegram, MixPay, and any future processors) for the actual processing of card, crypto, and electronic payments. Each partner enforces its own KYC, AML, and fraud-prevention measures in addition to ours. By transacting on the Services you agree to comply with the partner's terms and to provide any information they require.

8. Chargebacks and Disputes

If you initiate a chargeback rather than contacting us first (see Refund Policy), we may:

• Dispute the chargeback with evidence of delivery and account activity
• Suspend or terminate the affected account
• Add the email and payment instrument to a block list to prevent future purchases
• For repeated chargebacks indicative of "friendly fraud," refer the activity to fraud-prevention databases and, where appropriate, law enforcement

9. Cryptocurrency

When you pay with cryptocurrency through one of our supported processors (e.g. MixPay), the processor handles on-chain analysis (Chainalysis / equivalent) and screens the sending wallet against known illicit-activity lists. Wallets connected to mixers, sanctioned addresses, ransomware payments, or other high-risk activity are blocked at the processor level. We don't override these blocks.

10. Employee Training and Internal Controls

Personnel with access to financial systems, KYC data, and fraud-review tools receive AML and fraud-prevention training appropriate to their role. Access is controlled on a least-privilege basis and logged for audit. We retain records sufficient to support regulatory inquiries for at least 5 years (or longer where local law requires).

11. Reporting Obligations

We file Suspicious Activity Reports and equivalent regulatory notices where required by law. We cooperate with law-enforcement inquiries presented through valid legal process (subpoenas, court orders, MLATs, etc.).

12. Reporting Suspected Fraud or Abuse

If you suspect financial fraud or abuse on the Services (including a compromised account, a fraudulent charge, or a fellow user attempting to launder funds), report it immediately to support@honeypot.com. Include transaction IDs, dates, and any supporting evidence.

Contact

support@honeypot.com

OCAI LTD
Nicosia, Cyprus