Licens.

Legal / AML and KYC Policy

AML and KYC Policy

G&L I/S · licens.tech · Draft pending professional review

Platform: Licens (licens.tech) — G&L I/S Version: 1.0 Effective date: [TO BE INSERTED]

Important: This policy describes G&L’s operational controls. It does not assert that G&L is a obliged entity under the Danish Anti-Money Laundering Act for all activities. Payment-institution AML/KYC obligations primarily sit with Stripe.

1. Purpose

Reduce fraud, sanctions exposure, and abuse of the marketplace while keeping identity document storage with Stripe wherever possible.

2. Allocation of roles

| Activity | Primary actor |
|---|---|
| Payment KYC / identity docs for payouts | **Stripe Connect** |
| Card payment monitoring | **Stripe** (+ G&L review of signals) |
| Seller eligibility (18+, country support) | G&L + Stripe |
| Lawful-source attestation for keys | G&L (contractual) |
| Sanctions geo-blocking of storefront | G&L |
| Suspicious marketplace patterns (stolen keys rings, mule accounts) | G&L operations |

3. Seller verification standard

3.1 Sellers must complete Stripe Connect onboarding before payouts.

3.2 G&L stores: Stripe account id, charges enabled / payouts enabled flags, country, business type, and limited profile fields — not passport/ID image files by default.

3.3 Business Sellers should provide accurate legal name and company identifiers (e.g., CVR/VAT where applicable).

3.4 Private Sellers are allowed but may receive tighter velocity limits and enhanced manual review.

4. Buyer checks

4.1 Standard account + payment authentication (e.g., 3-D Secure where applicable via Stripe).

4.2 Minors may buy subject to Buyer Terms; additional friction may apply.

5. Risk indicators (examples)

  • burst listing of high-value keys from new accounts;
  • high rate of “already redeemed” disputes;
  • mismatched geolocation / many devices;
  • sanctions-country attempts;
  • chargeback spikes;
  • refusal to cooperate with order investigations.

Actions: listing freeze, payout delay, holdback increase, suspension, ban, report to Stripe, and—only if legally required—authority notification.

6. Sanctions

G&L blocks sanctioned territories/persons to the extent operable via geo/IP, self-declared country, and Stripe controls. Sellers must not circumvent controls.

7. Recordkeeping

Keep account, order, dispute, and enforcement logs for periods required by bookkeeping/platform law and Stripe requirements. Avoid retaining ID scans.

8. Training and ownership

Partners of G&L I/S share responsibility for enforcing this policy until a compliance owner is designated. Escalation path: operations → partners → counsel/Stripe support.