POLICY
1. PURPOSE
This AML & Identity Verification Policy (“Policy”) establishes the principles under which Infee may verify user identity and prevent misuse of the Platform for unlawful activities.
This Policy forms an integral part of the Master Terms of Use, Influencer Agreement, Merchant Agreement, and Commission & Payout Policy.
Infee is not a financial institution. However, due to payout facilitation and regulatory obligations, Infee may implement risk-based identity and compliance controls.
2. SCOPE
This Policy applies to:
- Influencers receiving payouts
- Merchants settling commission obligations
- Agencies acting on behalf of Merchants
Identity verification may be required before:
- first payout,
- payout above a certain threshold,
- suspicious activity investigation,
- regulatory reporting (including DAC7 compliance).
3. IDENTITY VERIFICATION (KYC)
Infee may request:
For Individuals:
- Government-issued ID
- Proof of residence
- Tax Identification Number (TIN)
- Date of birth
For Legal Entities:
- Company registration extract
- VAT number
- Identification of beneficial owner(s)
- Authorized representative documentation
Failure to provide requested documentation may result in:
- payout suspension,
- account restriction,
- termination.
4. RISK-BASED APPROACH
Infee applies a proportional, risk-based approach.
Enhanced verification may apply where:
- unusually high transaction volumes occur,
- multiple accounts are linked,
- inconsistent tax residency data is detected,
- fraud indicators are present.
Infee reserves the right to determine risk level at its discretion.
5. PROHIBITED USE
The Platform may not be used for:
- money laundering,
- terrorist financing,
- sanctions evasion,
- fraudulent financial activity,
- identity concealment.
If unlawful use is suspected, Infee may:
- freeze funds,
- suspend the account,
- report to competent authorities if legally required.
6. SOURCE OF FUNDS
Infee may request reasonable confirmation regarding the source of funds where required to comply with legal obligations or mitigate financial crime risk.
7. SANCTIONS COMPLIANCE
Users must not:
- be subject to EU or international sanctions,
- operate from restricted jurisdictions,
- transact on behalf of sanctioned persons.
Infee may screen users against applicable sanctions lists.
8. WITHHOLDING RIGHTS
Infee reserves the right to:
- temporarily withhold payouts,
- maintain reserve balances,
- delay payments pending compliance review.
Such measures do not constitute breach of contract.
9. DATA PROCESSING
Personal data collected for AML or identity verification purposes shall be processed in accordance with the Privacy Policy and applicable data protection laws.
10. LIMITATION OF LIABILITY
Infee shall not be liable for losses resulting from:
- account suspension due to compliance review,
- delayed payouts due to verification,
- regulatory reporting obligations.
11. POLICY UPDATES
Infee may update this Policy in response to regulatory developments or operational risk assessments.
Continued use of the Platform constitutes acceptance of updates.