AuctionPass
Legal

KYC / AML Policy

How we verify members and prevent financial crime.

Last updated: replace with your effective date.

Verification requirement

Every member completes identity verification before bidding. We collect and verify identity documents through our verification partner to confirm you are who you say you are.

Sanctions & watchlist screening

As part of onboarding we screen applicants against government sanctions and watchlists (including OFAC) and politically-exposed-person (PEP) lists.

Ongoing monitoring

We may re-screen members periodically and monitor activity for patterns consistent with fraud or money laundering.

Recordkeeping

We retain verification and transaction records to meet anti-money-laundering and other regulatory obligations.

Enforcement

Accounts with confirmed matches or suspicious activity are blocked, and we report as required by law. We may refuse or reverse transactions to remain compliant.

This is placeholder language, not legal advice. Replace with your finalized, counsel-reviewed compliance program before launch.

KYC / AML Policy • AuctionPass