1. OBJECTIVE OF THE AML POLICY
EduCrafter Labs Ltd is committed to full compliance with all applicable anti-money laundering (AML) and counter-terrorist financing (CTF) regulations in its operations. All our employees and representatives adhere to the highest AML and Know Your Customer (KYC) standards to minimize the risk that our services may be used to facilitate financial crimes.
Payment services are provided by Marvli Payment OÜ (company number 16338540), a regulated entity registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Service Business (MSB) under registration number M24723823.
EduCrafter Labs Ltd (hereinafter referred to as “Walletorix”, “we”, “us”, or “our”) is a company incorporated under the laws of England and Wales with company number 15388035 and having its registered office at 85 Great Portland Street, First Floor, London, England, W1W 7LT.
Whilst Marvli Payment OÜ is the issuer of accounts and the primary provider of payment services, Walletorix acts solely as an agent and partner platform of Marvli Payment OÜ.
This AML Policy establishes the framework and measures designed to ensure the security, transparency, and compliance of Walletorix operations. We pledge to adhere to applicable Canadian AML legislation, UK regulatory requirements, and internationally recognized AML and CTF standards.
2. WHAT IS AML POLICY?
The AML Policy defines the principles and procedures designed to prevent the misuse of our platform for money laundering, terrorist financing, or any other unlawful activities.
KYC processes form a crucial part of our AML framework. Their goal is to ensure that we correctly identify and understand our customers and manage risk effectively throughout the customer lifecycle.
In cases where potentially suspicious or unusual transactions or client behavior are identified, Walletorix takes all necessary measures to mitigate such risks. Relevant personnel may request additional documentation, such as proof of source of funds, business justification, or enhanced due diligence (EDD) information.
We maintain structured records of all identification documents, verification details, and transaction data. All information is stored securely and handled in compliance with applicable data protection laws.
Our AML Policy includes:
- Identification and verification of customers prior to establishing any business relationship;
- Risk-based customer due diligence (CDD) and enhanced due diligence (EDD) for high-risk customers;
- Continuous transaction monitoring to detect and prevent suspicious activity;
- Procedures for internal and external reporting of suspicious transactions to the appropriate authorities;
- Regular AML and compliance training for all relevant personnel.
During the customer due diligence process, Walletorix reserves the right to reject documentation, deny account activation, or terminate business relationships if suspicious activity, falsified information, or non-cooperation is identified.
Walletorix operates in accordance with Marvli Payment OÜ’s AML and KYC compliance program, ensuring that all activities meet applicable laws, regulations, and international best practices. Verification and due diligence for Walletorix clients are conducted under the oversight of Marvli Payment OÜ.
3. SCOPE OF THE AML POLICY
This AML Policy covers, but is not limited to, the following key components:
- Customer identification and verification prior to establishing a business relationship;
- Risk-based customer due diligence (CDD), including enhanced due diligence (EDD) for higher-risk clients;
- Continuous monitoring of customer transactions and account behavior to detect inconsistencies or suspicious patterns;
- Internal and external reporting procedures for suspicious activity;
- Comprehensive AML and compliance training for employees, agents, and partners.
All AML and compliance operations are conducted within the framework of Marvli Payment OÜ’s AML program, and Walletorix follows its internal compliance policies accordingly.
During the due diligence process, Walletorix reserves the right to reject customer documents, delay account activation, or terminate relationships in the event of suspicious behavior, falsified information, or lack of cooperation.
Marvli Payment OÜ is responsible for reviewing Walletorix clients’ KYC/KYB documentation and ensuring continued compliance with AML requirements.
The list of prohibited and restricted countries is available in the Prohibited Countries List (PDF) (attached separately).
For identity verification, sanctions screening, and ongoing compliance monitoring, Walletorix and Marvli Payment OÜ utilize the services of Finchecker, a regulated verification and compliance technology provider. Finchecker supports customer verification, global sanctions and watchlist screening, and ongoing due diligence in line with international AML standards and regulatory obligations.
4. RESPONSE TIMES
Requests related to AML matters — including verification, compliance reviews, disputes, or other AML-related inquiries — are typically processed within up to fifteen (15) business days. The same timeframe may apply to account activation, re-verification, or compliance-related assessments, depending on the case complexity and level of due diligence required.
For any AML-related questions or compliance inquiries, please contact our Compliance Department at [email protected].
(The list of prohibited and restricted countries is available in the Prohibited Countries List (PDF)