Anti-Money Laundering & Transaction Laundering Policy and Procedures

Last Modified: 06/23/2026

1. Purpose and Commitment.
   1. SexAndRelationshipAdvice.com (“We,” “Us,” or the “Company”) is committed to conducting business in compliance with all applicable anti-money laundering (“AML”), counter-terrorist-financing, economic-sanctions, and transaction-laundering laws, regulations, and the rules of the card networks and payment processors through which transactions on Our Site are processed (“Card Brand Rules”).
   2. The purpose of this Policy is to prevent the use of Our Site and Services for money laundering, transaction laundering, terrorist financing, sanctions evasion, fraud, or any other illegal financial activity, and to describe the procedures We use to detect, deter, and report such activity.
   3. This Policy applies to all Users of the Site, including all Visitors, Customers, Callers, and Talkers, and to all transactions conducted through the Site.
2. Definitions.
   1. Money Laundering means the process of making illegally obtained proceeds appear legitimate, generally involving the placement, layering, and integration of unlawful funds into the financial system.
   2. Transaction Laundering (also known as “factoring,” “aggregation,” or “processing laundering”) means knowingly or unknowingly processing payment card transactions on behalf of another merchant or for goods or services that were not disclosed to, or approved by, the acquiring bank or payment processor — including the use of Our payment credentials or accounts to process transactions for an unrelated business or for prohibited products or services.
   3. KYC / Customer Due Diligence (CDD) means the procedures used to verify the identity, age, and legitimacy of Users, as further described in Our Age Verification & KYC Policy.
   4. Beneficial Owner means any individual who ultimately owns or controls a User account or who receives payouts from the Site.
3. Program Governance.
   1. We have designated an AML Compliance Officer responsible for the implementation, oversight, and ongoing administration of this Policy, including staff training, monitoring, escalation, and coordination with Our financial partners and law enforcement.
   2. Relevant personnel receive periodic training on the identification and handling of suspicious activity, the requirements of this Policy, and applicable Card Brand Rules.
   3. This Policy is reviewed periodically and updated as necessary to reflect changes in law, regulation, Card Brand Rules, and Our business.
4. Customer Identification & Due Diligence.
   1. Before a User may receive payouts or sell content or services on the Site, We verify the User’s identity and age and collect supporting documentation in accordance with Our Age Verification & KYC Policy.
   2. We collect and maintain payout information and may require additional documentation to confirm the identity and legitimacy of any User or beneficial owner.
   3. We screen Users against applicable government sanctions and watch lists (including, where applicable, lists maintained by the U.S. Office of Foreign Assets Control (“OFAC”)) and decline or terminate accounts that present an unacceptable risk.
   4. We apply enhanced due diligence to higher-risk Users, including those whose activity is inconsistent with their stated business or whose transactions exhibit one or more of the red flags described below.
5. Prohibited Activity. The following are strictly prohibited and will result in account termination, forfeiture of funds, and, where required, reporting to Our financial partners and the appropriate authorities:
   1. Transaction laundering of any kind, including using a Site account or Our payment credentials to process payments for another person or business, or for goods, services, or content not legitimately offered through that account on the Site;
   2. Submitting, facilitating, or assisting any transaction that misrepresents the nature of the goods or services being sold, the identity of the seller, or the merchant category of the transaction;
   3. Using the Site to convert, transfer, or conceal the proceeds of unlawful activity, or to finance any unlawful activity;
   4. Structuring transactions to evade reporting thresholds, monitoring, or Card Brand Rules;
   5. Processing transactions for, or on behalf of, any individual or entity subject to economic sanctions; and
   6. Selling or processing payment for any product, service, or content prohibited by this Site’s Terms and Conditions or Card Brand Rules.
6. Monitoring & Red Flags.
   1. We monitor transactions and account activity for indicators of money laundering and transaction laundering. Indicators (“red flags”) include, without limitation:
      • transaction patterns or volumes inconsistent with a User’s profile or stated activity;
      • multiple accounts sharing payout details, devices, or identifying information;
      • chargeback, refund, or dispute rates that suggest fraud or laundering;
      • payouts directed to third parties unrelated to the account holder;
      • attempts to route payment for off-platform or undisclosed goods or services through the Site; and
      • use of the Site by, or on behalf of, sanctioned persons or jurisdictions.
   2. Activity that triggers a red flag is escalated to the AML Compliance Officer for review, and may result in a hold on funds, a request for additional information, suspension, or termination.
7. Reporting & Cooperation.
   1. Where required by law, We file or support the filing of suspicious activity reports and cooperate with law enforcement, regulators, and Our financial partners in connection with investigations of suspected money laundering, transaction laundering, or related illegal activity.
   2. We may disclose User and transaction information to Our financial partners, the card networks, and the appropriate authorities to the extent required or permitted by law and Our Privacy Policy.
8. Recordkeeping.
   1. We retain identity-verification records, transaction records, and AML-related documentation for the period required by applicable law and Card Brand Rules.
9. Enforcement.
   1. Violation of this Policy is a material breach of Our Terms and Conditions and may result in immediate suspension or termination of access, forfeiture of funds, and referral to Our financial partners and the appropriate authorities.
10. Questions & Reports.
    1. Questions about this Policy, or reports of suspected money laundering or transaction laundering on the Site, may be directed to Us at support@sexandrelationshipadvice.com.