AML Policy
Effective Date: 01.05.2026
Provider: 2Way OU, doing business as Groovl
Website: https://www.groovl.com
1. Overview
This AML Policy explains how Groovl reviews payments and transactions to reduce fraud, money laundering, sanctions, and other financial crime risks.
Groovl may use third-party AML and transaction risk tools to screen payments, wallets, transactions, and related activity.
By making a payment to Groovl, you agree to this AML Policy.
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2. Transaction Risk Review
Groovl may review any payment or transaction before Credits are added to your account balance.
A transaction may be delayed, rejected, held, returned, or require additional verification if Groovl considers it suspicious, high-risk, inaccurate, incomplete, or otherwise unacceptable.
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3. Risk-Based Handling
If a transaction receives an overall risk score greater than 35%, Groovl may apply an additional review or require KYC before processing the payment.
If the high-risk portion of a transaction exceeds 1%, Groovl may hold the transaction and require KYC before processing, crediting, or returning the payment.
Groovl may refuse to credit or accept any transaction that presents an unacceptable AML, sanctions, fraud, legal, operational, or reputational risk.
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4. KYC and Return of Funds
If KYC is required, Groovl may request identity verification, payment verification, source-of-funds information, supporting documents, or other information.
If KYC is not completed to Groovl’s satisfaction, Groovl may refuse the transaction, restrict the account, suspend services, or refuse future service.
Where legally and technically possible, Groovl may return held funds after completing the required review.
Any returned amount may be reduced by blockchain fees, network fees, bank fees, processor fees, risk-review costs, or other transaction-related costs.
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5. Payment Accuracy
You are responsible for making payments accurately and in accordance with the payment instructions shown by Groovl.
Incorrect, incomplete, underpaid, overpaid, expired, high-risk, or otherwise irregular payments may be delayed, rejected, held, returned, or require additional verification.
Groovl is not responsible for losses, delays, fees, exchange-rate differences, blockchain fees, network fees, bank fees, processor fees, or other costs caused by inaccurate or irregular payments.
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6. Changes to This Policy
Groovl may update this AML Policy from time to time.
The updated policy will be published on Groovl.com or made available inside your Groovl account.
Your continued use of Groovl after the updated policy becomes available means that you accept the updated policy.