AML/CFT and Restricted Jurisdictions Policy

1. Purpose and scope

This Policy explains the controls and rules that Polee uses to reduce the risk that its services are used for money laundering, terrorist financing, proliferation financing, fraud, stolen payment instruments, illicit wallets, or concealment of the proceeds of unlawful activity.

It applies to users, Author applicants and Authors, media buyers where their separate agreement applies, deposits and balance top-ups, internal balance movements, withdrawals and payouts, and other financial operations made through Polee. It supplements the Terms of Use, the Offer for Authors, and other applicable Polee agreements.

2. Identity and age verification

In Polee’s normal onboarding flow, Author applicants undergo identity and age verification before receiving ordinary Author status. The normal application includes location information, identity-document details, date of birth, and verification media, and is reviewed manually. Applicants under 18 are rejected, and a document number already used for another account cannot be accepted.

In exceptional cases, an authorized administrator may make a separate manual status decision with a recorded reason. Polee does not represent this as the same technical path or an identical evidence set. This exception does not remove Polee’s right to request information reasonably needed to identify the user, review an operation, or enforce this Policy.

The Author verification consent presented in the service describes facial verification media and comparison with the identity-document photograph as biometric facial data. Polee’s current ordinary verification flow includes manual administrator review. Polee does not state in this Policy that every comparison is automated, that Polee operates a universal biometric-matching system, or that the process includes government-database verification, sanctions or politically exposed person screening, or a repeated identity check for every withdrawal.

3. Financial controls

Earnings holds

Credits that are subject to Polee’s configured earnings-hold rule — including Author earnings currently received through qualifying internal transfers — remain unavailable for withdrawal during the applicable hold period. The hold gives Polee time to consider complaints, reversals, violations, and signs of an improper operation before the relevant earnings are released.

Polee’s ordinary production hold period for qualifying earnings is seven days. Polee may apply a longer hold to a particular credit when the relevant earning is credited if additional time is required to review or investigate the operation.

This does not mean that every wallet deposit, balance top-up, or payment-database transaction is placed on hold. Whether a credit is held depends on its type and the applicable rule for the recipient account.

Manual withdrawal review

Under Polee’s standard creator payout flow, payout access is limited to Author, Manager, and Channel accounts; an account registered only as an ordinary user cannot request a payout. An ordinary Author applicant receives Author status only after completing Polee’s identity and age verification (KYC). Manager and Channel accounts follow their applicable verification and approval flows. Polee does not repeat KYC automatically for every payout request.

The separate Media Buyer payout flow is governed by the applicable Media Buyer agreement. Current role-gated access includes pre-media buyers, whose payout is capped, and verified Media Buyers. This separate contractual flow does not make payout available to ordinary user accounts.

Every user-initiated withdrawal or payout request from an account with payout access submitted through Polee’s standard payout service is placed into monitoring and is subject to manual review. The amount remains blocked and is not sent to the payment provider unless an authorized administrator approves the request. Polee may reject or cancel a request when the review is not completed satisfactorily or the operation would breach this Policy or another applicable agreement.

Earnings cannot be included in a payout request until any applicable earnings hold has ended. After eligible funds are requested for payout, the requested amount is blocked separately while an authorized administrator reviews the request.

Records and traceability

Polee’s ledger records the amount, currency, time, category, and balance effect of internal money movements. Where a movement is transaction-based, Polee also retains its transaction identifier and state and links it to the immediate recorded basis of account movements, such as a deposit, payout, transfer, fee, refund, or reversal. Administrative balance adjustments are recorded with the information supported by the relevant flow. These records allow Polee to reconstruct the sequence and direct recorded basis of internal ledger movements.

Internal ledger records do not constitute independent verification of the external source of funds or unit-by-unit attribution after funds from different operations have been combined in one balance. They do not provide cryptographic tamper proofing. Retention of these records is governed by Section 7 and the Privacy Policy.

Deposited funds and withdrawals

Funds added through a user deposit cannot be withdrawn directly. An account with payout access may request a payout only from the part of its total balance that exceeds the remaining unspent deposit amount. A completed internal transfer that spends the account’s balance reduces both the balance and that remaining deposit amount; a supported refund or reversal may also adjust it.

Example: an account with payout access has a deposit of 100 units. The balance is 100 and the remaining deposit amount is 100, so none is available for payout. If the account spends 40 through a completed internal transfer, the balance and remaining deposit amount each become 60. If the account then earns 30 and those earnings have completed any applicable hold, the balance is 90 while the remaining deposit amount is 60. Up to 30 may be requested for payout, subject to manual review and the other withdrawal controls in this Policy.

Maximum user account balance

Polee applies a configurable maximum to the aggregate user account value across the user’s currency accounts. For this check, account balances and amounts already reserved for outgoing operations are converted to the configured limit currency. A user deposit request that would exceed the limit is rejected, and the limit is checked again before deposit processing. A positive credit to a user, such as earnings from an internal transfer, remains on hold and unavailable for spending or withdrawal while releasing it would exceed the maximum.

The current user-facing maximum is published in About wallet. Because the limit is configuration-controlled, this Policy does not promise that one numerical amount will apply permanently. The described checks apply to user deposits and release of positive held entries; this Policy does not describe them as a universal cap on administrative or non-user balance adjustments.

Other controls

Polee can restrict particular account operations, block a deposit wallet, apply configured payout limits, and cancel, reject, reverse, or refund supported operations where the relevant payment flow permits it.

These controls do not mean that Polee operates automated suspicious-activity scoring or performs an external source-of-funds investigation for every operation.

4. Restricted jurisdictions

Polee uses the FATF public statements dated 19 June 2026 as the source for the formal high-risk and increased-monitoring groups below. The categories are kept separate because FATF applies different language to them.

FATF high-risk jurisdictions subject to a call for countermeasures

Democratic People’s Republic of Korea (DPRK)
Iran

FATF high-risk jurisdiction subject to enhanced due diligence, not countermeasures

Myanmar

FATF jurisdictions under increased monitoring

Angola
Bolivia
Bosnia and Herzegovina
Bulgaria
Cameroon
Côte d’Ivoire
Democratic Republic of the Congo
Haiti
Iraq
Kenya
Kuwait
Lao People’s Democratic Republic (Lao PDR)
Lebanon
Monaco
Nepal
Papua New Guinea
South Sudan
Syria
Venezuela
Vietnam
Virgin Islands (UK)
Yemen

FATF does not call for enhanced due diligence solely because a jurisdiction is under increased monitoring and asks countries to apply a risk-based approach rather than wholesale de-risking. Polee nevertheless applies the prohibition in this Policy as its own stricter platform risk rule.

Additional Polee withdrawal-only restrictions

Russian Federation
Belarus

The Russian Federation and Belarus are not included in either formal FATF list dated 19 June 2026. Polee includes them as separate withdrawal-only platform restrictions.

Sources for the FATF groups

5. Effect of the restrictions

For this Policy, a financial operation is associated with a restricted jurisdiction when the user is resident or located there; a relevant payment account or instrument is maintained or issued there; a relevant financial institution is located there; or the origin or destination of the operation is there. Citizenship alone, without one of these connections, is not a criterion under this Policy.

For the funding restriction below, a FATF-listed jurisdiction means a jurisdiction in one of the first three groups in Section 4: the countermeasures group, the enhanced-due-diligence group, or the increased-monitoring group.

A user must not make or receive a deposit or balance top-up that is associated with a FATF-listed jurisdiction.

Deposits and balance top-ups associated with the Russian Federation or Belarus are permitted under this Policy. This permission does not override the other controls in this Policy, a payment provider’s requirements, or another applicable agreement.

A user must not request or receive a withdrawal or payout that is associated with any jurisdiction listed in Section 4, including the Russian Federation and Belarus.

A user must not circumvent these restrictions through another person, another account, an intermediary, misleading location or payment details, or any arrangement intended to conceal a restricted connection.

Polee determines whether an operation has a restricted association using information reasonably available to it. These are contractual financial-operation rules. For payouts, they may be applied through the manual review described above; other controls may be used only where the relevant payment flow supports them. This does not mean that every jurisdictional connection is screened or blocked by a universal automated country-control system. This Policy does not itself prohibit ordinary browsing or account registration solely because of a listed jurisdiction.

6. Review and response

When Polee identifies a possible breach or needs more information to review an operation, it may delay, reject, hold, restrict, block, cancel, reverse, refund, or suspend the relevant operation or account to the extent supported by the applicable flow and permitted by the Terms or another applicable agreement. Polee may ask for information reasonably necessary to understand the operation, account, parties, payment instrument, origin, or destination.

Polee may preserve relevant records and cooperate with competent authorities where permitted or required by applicable law and the Privacy Policy. This Policy does not claim a particular regulatory status, FATF endorsement, or operation of a universal automated watchlist or regulatory-reporting system.

7. Records, privacy and updates

Identity and financial records are retained for the purposes and periods described in the Privacy Policy. Depending on the purpose and applicable legal or reporting requirements, some identity-verification and financial-reporting records may be retained for up to seven years. This does not create a promise of one fixed or indefinite retention period for every record.

Polee will review the public jurisdiction list when it adopts an updated FATF list or changes its own additional restrictions. A changed external FATF statement does not silently amend this page; the published policy must be updated.

Questions about Polee’s internal ledger records, holds, withdrawal reviews, account decisions, or this Policy may be sent to [email protected]. Questions about full payment-card processing or a payment provider’s own services should be directed to the relevant provider or bank.