AML & KYC Policy

This policy explains the anti-money-laundering (AML) and know-your-customer (KYC) practices Z2Deal applies, why they exist, and what they mean practically for buyers and sellers using the Platform.

Why a marketplace like this needs an AML policy at all

Any platform that holds funds on behalf of users and processes payouts between strangers is a potential vector for moving illicit funds, whether or not that's ever the intent of most users. Cryptocurrency payment rails in particular attract regulatory attention precisely because they can make tracing the origin of funds harder than traditional banking. We take reasonable, proportionate steps to reduce this risk - not because we assume bad intent from any specific user, but because a platform that ignores this risk entirely tends to attract exactly the kind of activity that eventually gets the whole platform shut down or sanctioned, which hurts every legitimate user in the process.

When identity verification (KYC) is triggered

Identity verification - submitting a clear photo of a government-issued ID such as a passport, driver's license, or national identification card - may be required in a few situations: before a seller is approved for certain categories considered higher-risk; before a withdrawal above a certain amount or frequency is approved; or when our internal monitoring flags unusual activity on an account, such as an atypical pattern of deposits and immediate withdrawals. Being asked to verify isn't an accusation - it's a standard checkpoint that many legitimate accounts will pass through as a normal part of using the Platform at any meaningful scale.

What we actually check

Verification confirms that the name on a submitted ID reasonably matches the account information provided, that the document appears genuine and current (not visibly altered or expired), and that the document type is one we accept. We don't run third-party credit checks or pull external financial records as part of this process - the scope is limited to confirming identity, not building a broader financial profile of you.

Transaction monitoring

We monitor account activity for patterns commonly associated with money laundering or fraud - rapid movement of funds in and out with no genuine trading activity in between, structuring deposits or withdrawals to stay just under a review threshold, multiple accounts that appear to be coordinated, or transaction volumes wildly inconsistent with an account's stated activity. Flagged activity triggers a manual review by a person, not an automatic, irreversible account action - a flag means we look closer, not that we assume guilt.

What happens when a withdrawal is held for review

If a withdrawal is held pending verification or review, the funds remain in your account balance - they aren't seized or forfeited, just paused while we confirm what's needed. You'll typically be notified of what's required to release the hold, whether that's an identity document, a brief explanation of unusual activity, or simply the standard processing time for a review. Most holds resolve within a reasonable timeframe once the requested information is provided.

Sanctioned individuals and prohibited jurisdictions

We do not knowingly provide services to individuals or entities on relevant government sanctions lists, or facilitate transactions that would violate applicable trade sanctions. Where a jurisdiction is subject to comprehensive sanctions that would make providing services there unlawful, we restrict access accordingly. This is a baseline compliance requirement for any platform processing payments internationally, not a judgment about any individual user.

Record keeping

We retain transaction records and verification documentation for the period required by applicable anti-money-laundering regulation, which is often longer than our general data retention period for other account information - this is a legal requirement we don't have discretion to shorten just because a user requests earlier deletion. See our Privacy Policy for how this interacts with broader data deletion requests.

Reporting obligations

Where required by law, we may be obligated to report certain transactions or patterns to relevant financial authorities, regardless of our own conclusions about whether something is actually suspicious - this is a standard part of how AML reporting frameworks function, and it's not something we can opt out of for any specific user as a courtesy.

What this means for ordinary buyers and sellers

For the vast majority of users, this policy is essentially invisible day to day - you buy, you sell, you withdraw, and nothing about the process changes. Verification typically only becomes relevant once you're withdrawing meaningful amounts as a seller, or if your account is genuinely flagged for an unusual pattern. Treat a verification request as routine, respond promptly with what's asked for, and the process is generally straightforward.

Questions about a specific hold or verification request

Contact us through our Contact page with "Verification / AML" in the subject and your account details, and we'll explain what's specifically needed to move your case forward.

Document types we accept

Acceptable identity documents typically include a current passport, a government-issued driver's license, or a national identification card - whichever is standard for your country of residence. The photo or scan needs to clearly show your full name, date of birth, document number, and expiry date where applicable, with no corners cropped out and no glare obscuring the text. Documents that are expired, visibly altered, or too low-resolution to read clearly will be rejected and you'll be asked to resubmit, which is the most common reason a verification takes longer than expected - getting a clear photo right the first time saves a full review cycle.

How this policy gets updated

Anti-money-laundering regulation evolves, and the specific thresholds, document requirements, and monitoring practices described here may be adjusted over time to stay compliant with current law or to respond to new fraud patterns we observe on the Platform. We'll update this page when that happens; significant changes affecting how withdrawals work will also be communicated more directly rather than relying on users to check this page periodically.

A note on third-party verification providers

Identity verification may be processed with the assistance of a third-party verification service rather than purely manual review by our own staff, depending on volume and the specific check required. Any such provider is bound by appropriate data protection and confidentiality obligations, and documents shared with them are used solely for the verification purpose at hand, consistent with the rest of this policy.

Last updated: October 2026