P1 Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy

P1 Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy

Ensuring Financial Integrity, Transparency, and Regulatory Compliance

P1 is not a regulated financial services provider and does not conduct regulated investment activities. However, we are committed to supporting global efforts to prevent money laundering, terrorist financing and other forms of financial crime. As part of this commitment, we verify and record information that identifies each customer who reaches the payout stage of our programs.

Money laundering is the process of converting funds derived from illegal activities into assets that appear legitimate. Although P1 does not handle client funds for trading or investment purposes, we recognize that criminals may attempt to misuse online platforms for illicit financial activity. Our AML and CTF framework is designed to prevent such misuse and ensure that our services are not used to facilitate criminal conduct.

Money laundering typically involves three stages. The first stage, placement, involves introducing illicit funds into the financial system, often through bank deposits, money transfers or the purchase of high-value goods. Criminals may attempt to break large amounts into smaller deposits to avoid detection, a practice known as smurfing. The second stage, layering, involves moving funds between accounts or converting them into different instruments to obscure their origin. The third stage, integration, involves reintroducing the funds into the economy as seemingly legitimate assets or payments.

P1 adheres to AML principles and actively prevents any actions that aim to facilitate the legitimization of illegally obtained funds. Our policy is designed to prevent the use of our services by individuals or entities seeking to engage in money laundering, terrorist financing or other criminal activity. To support this objective, P1 does not accept or pay out cash under any circumstances. We reserve the right to suspend or terminate any customer activity that may be illegal or connected to money laundering in our assessment.

Company Procedures

P1 takes reasonable steps to ensure that it is dealing with real individuals and legitimate entities. We implement measures consistent with applicable AML and CTF standards, including those issued by international bodies and relevant authorities. Our AML framework is built on three core components: Know Your Customer (KYC) and due diligence, monitoring of customer activity, and record-keeping.

Know Your Customer (KYC) and Due Diligence

Because of our commitment to AML and KYC standards, every customer who reaches the payout stage must complete identity verification. We may apply enhanced due diligence to customers who reside in, or whose funds originate from, jurisdictions identified by credible sources as high-risk for money laundering, corruption or terrorist financing. We may also apply heightened scrutiny to beneficial owners associated with such jurisdictions.

P1 reserves the right to refuse to process a payout or any related transaction at any stage if we believe the activity may be connected to money laundering, terrorist financing or other criminal conduct. In accordance with international AML standards, P1 is not obligated to inform the customer if a report is made to relevant authorities.

Restricted & Sanctioned Jurisdictions

P1 welcomes customers from many regions; however, governmental restrictions, international sanctions and our internal risk policies prohibit us from onboarding or servicing customers from certain jurisdictions. P1 does not open accounts for residents and/or nationals, or entities associated with the following restricted or sanctioned jurisdictions: Afghanistan, Central African Republic, Congo (Brazzaville), Crimea, Cuba, Democratic People’s Republic of Korea (DPRK), Democratic Republic of Congo, Donetsk, Guinea, Haiti, Iran, Iraq, Libya, Mali, Myanmar (Burma), Puerto Rico, Russian Federation, Palestinian Territory, Syria, Somalia, South Sudan, Sudan, Ukraine, United States of America, United States Virgin Islands, Vatican City, Yemen. In addition, any countries on the FATF and EU/UN sanctions lists.

This list may be updated periodically based on international sanctions, regulatory guidance and P1’s internal risk assessments.

Monitoring of Customer Activity

P1 monitors customer behaviour for unusual, inconsistent or suspicious activity that may indicate attempts to circumvent our rules or misuse our services. This includes monitoring for irregular payout requests, inconsistencies in identity information, attempts to bypass verification, or activity linked to high-risk jurisdictions. Where necessary, P1 may request additional information or documentation to verify the legitimacy of customer activity.

Record Keeping

P1 maintains records of customer identification, verification documents, transaction history and AML-related decisions.

Right to Refuse or Suspend Activity

P1 reserves the right to refuse any transaction, suspend account activity, deny payouts or terminate customer access if we believe the activity may be linked to money laundering, terrorist financing, fraud or other criminal conduct. P1 is not obligated to inform customers if a report is made to authorities.