Documentation Index
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1. Introduction
This Anti-Money Laundering (hereinafter referred to as “AML”) Compliance Program is designed to outline the internal compliance systems, management processes, and risk control measures established by the Company to prevent, identify, monitor, and address potential money laundering, terrorist financing, financial fraud, sanctions evasion, and other illicit activities. The Company is committed to operating its global proxy IP and network infrastructure-related services in a lawful, compliant, transparent, and responsible manner, while adhering to applicable international laws, regulations, and industry best practices.2. Company Business Overview
The Company primarily provides the following network infrastructure and proxy-related technical services, including but not limited to:- Dynamic Residential Proxy Services
- Static Residential Proxy Services
- Rotating Proxy Network Services
- Global Network Routing and IP Allocation Services
- Data Access Optimization Services
- Enterprise-Grade Network Proxy Solutions
- Banking Services
- Custodial or Fund Safekeeping Services
- Cryptocurrency Exchange Services
- Remittance or Payment Settlement Services
- Gambling-Related Services
- Dark Web Services
- Anonymous Financial Services
3. AML Compliance Objectives
The primary objectives of this AML Compliance Program include:- Preventing the Company’s services from being utilized for illicit activities
- Identifying and mitigating risks associated with high-risk users and transaction behaviors
- Complying with international sanctions and related regulatory requirements
- Establishing appropriate Customer Identification (KYC) mechanisms
- Cooperating with legitimate regulatory and law enforcement investigative requests
- Safeguarding the legitimate rights and interests of both the platform and its users
4. Customer Due Diligence (CDD)
The Company employs a risk-based approach to its customer review and verification mechanisms. Based on a client’s risk level, the Company may collect the following information:- Name or business name
- Contact details
- Billing and payment information
- Government-issued identification
- Business registration documents
- Payment verification information
- Description of business use
- Clients engaging in large-value or high-frequency transactions
- Enterprise-level clients
- Users accessing the service from high-risk regions
- Anomalous transaction behavior
- Clients utilizing cryptocurrency for payments
- Accounts presenting a risk of misuse
5. Prohibited Activities
The Company strictly prohibits any user from utilizing the platform’s services to engage in the following activities:- Money laundering
- Terrorist financing
- Financial fraud
- Phishing
- Account theft
- Distribution of spam
- Distribution of malware
- Botnet-related activities
- Credit card fraud
- Unlawful cyberattacks
- Dark web-related activities
- Sanctions evasion
- Data scraping in violation of applicable laws
- Other activities that contravene international laws and regulations
6. Transaction and Behavior Monitoring
The Company has established internal risk monitoring mechanisms designed to identify suspicious behavior, including but not limited to:- Anomalous payment patterns
- Access attempts from high-risk regions
- Anomalous account registration patterns
- Anomalous bandwidth consumption
- Abuse of high-frequency IP rotation
- Risks associated with payment fraud
- Repeated payment failures
- Payment activities linked across multiple accounts
7. Sanctions Compliance
The Company adheres to applicable international sanctions regulations and may restrict or refuse to provide services to sanctioned individuals, entities, or regions, including but not limited to those listed on:- The U.S. OFAC Sanctions List
- The UN Sanctions List
- EU Sanctions Regimes
- Relevant UK sanctions regulations
8. Cryptocurrency Payment Compliance
When users utilize cryptocurrency for payments, the Company may implement additional risk control measures, including:- Blockchain transaction monitoring
- Payment risk assessment
- Fraud detection
- Wallet risk analysis
9. Data and Record Retention
In accordance with applicable laws and operational requirements, the Company will retain necessary business and compliance records, including but not limited to:- Payment records
- Order and billing records
- Login records
- IP allocation records
- KYC/Compliance review records
- Customer support communication records
10. Cooperation with Regulators and Law Enforcement
To the extent required by laws and regulations, the Company may cooperate with legitimate investigative requests from regulatory bodies, financial institutions, and law enforcement agencies. The Company reserves the right to:- Suspend accounts suspected of non-compliance
- Restrict anomalous transaction activities
- Provide information to the extent required by law
- Conduct internal investigations into suspicious activities
11. Internal Compliance Controls
The Company has established internal compliance and security management mechanisms, including:- Risk account review mechanisms
- Platform abuse monitoring systems
- Access controls
- Security logging
- Internal escalation procedures
- Compliance review mechanisms
12. Policy Updates
This AML Compliance Program may be updated in response to the following circumstances:- Changes in laws and regulations
- Changes in industry compliance requirements
- Adjustments to business operations
- The emergence of new types of risks