Anti-Money Laundering (AML) Policy

1. Introduction

BlushFans is operated by HEVEA TORUS LTD (Cyprus, registration number HE 487534) ("the Company"), which is committed to the highest standards of compliance against money laundering (ML). Our policy is designed to prevent our platform from being used to facilitate the movement of illicit funds, ensure compliance with applicable AML laws — including anti-money laundering laws applicable in Cyprus — and adhere to international standards (FATF).

Identity verification (KYC) for all creators worldwide is centrally managed by HEVEA TORUS LTD through our verification partner Sumsub.

2. Know Your Customer (KYC) Procedures

Before any "Creator" (Seller) can withdraw funds from BlushFans, they must undergo a mandatory verification process.

2.1 Customer Identification

• Individual Creators: Must provide a government-issued ID (Passport, National ID, or Driver's License) and a "liveness" check (selfie).
• Business Entities: BlushFans does not allow onboarding of businesses.

3. Transaction Monitoring

BlushFans utilizes automated systems to monitor transactions in real-time for suspicious patterns, including:

• Rapid Cycling: High-frequency transactions from the same IP or credit card.
• Irregular Pricing: Selling a low-value file (e.g., a blank PDF) for an unusually high price.
• Geographic Discrepancies: A seller in Country A receiving 90% of payments from "stolen" cards in Country B.
• Self-Dealing: A user attempting to buy their own content to move funds between accounts.

4. Prohibited Activities

BlushFans strictly prohibits the use of its platform for:

• Money laundering or "smurfing" (breaking large sums into small transactions).
• Financing of any illegal activity or terrorist group, human trafficking, or sex trafficking.
• Sale of content that violates our Usage Policy (e.g., illegal materials, non-consensual imagery).
• Transactions originating from or destined for high-risk/non-cooperative jurisdictions.

5. Record Keeping

In accordance with legal requirements, BlushFans maintains records of:

• Identity verification documents.
• Transaction history (amount, date, parties involved).
• Internal investigations into suspicious behavior.

These records are retained for a minimum of ten (10) years after the termination of the business relationship.

6. Contact

For questions regarding this policy or to report suspicious activity, please contact our Compliance Team at: xxxxxxxxxxxxxxxxxx.