1. Purpose
1Locol Technologies LTD (“1Locol”, “we”, “us”, or “our”) is committed to preventing the use of its platform and services for money laundering, terrorist financing, sanctions evasion, fraud, or other financial crime.
This public policy describes the high-level controls 1Locol applies to identify, assess, monitor, and escalate financial-crime risk.
It does not disclose confidential monitoring rules, risk thresholds, investigation procedures, or other controls that could undermine the effectiveness of our compliance programme.
2. 1Locol’s Role
1Locol is a travel technology and payment-orchestration platform.
Where regulated payment, custody, stablecoin conversion, money transmission, local settlement, or payout services are made available through 1Locol, those services may be provided by appropriately licensed or regulated third-party providers, subject to availability, eligibility, and the provider’s applicable terms.
1Locol does not represent that it holds a payment, money-transmission, electronic-money, or other regulatory licence unless expressly stated.
Regulated providers remain responsible for the regulatory obligations applicable to the financial services they provide.
1Locol maintains its own policies, controls, risk assessment, oversight, and escalation processes appropriate to the activities it performs.
3. Risk-Based Approach
1Locol applies a risk-based approach to financial-crime prevention.
Risk may be assessed using factors including:
- customer identity and verification status;
- customer location and jurisdiction;
- transaction amount and frequency;
- source and destination of funds;
- payment method;
- beneficiary information;
- transaction and account history;
- device and security information;
- sanctions and politically exposed person screening results;
- geographic and corridor risk;
- fraud indicators;
- behavioural and velocity indicators; and
- information provided by regulated service providers.
Controls may vary according to the risk associated with a customer, transaction, product, service, jurisdiction, or payment route.
4. Customer Due Diligence and Identity Verification
Where identity verification is required, 1Locol may require customers to complete customer due diligence before accessing certain services or transaction limits.
1Locol uses Didit as its only active KYC/identity-verification provider. Didit supports:
- identity-document verification;
- liveness checks;
- sanctions screening;
- politically exposed person (PEP) screening; and
- other screening where supported or configured.
Third-party providers supply verification and screening information, but 1Locol retains responsibility for its own risk decisions, escalation and service-access decisions.
Checks may include repeat or ongoing screening where configured, required by risk, or required for a service/payment corridor.
Previously collected KYC information may support future payment-corridor activation. Before reuse, it must be reassessed for validity, suitability and the relevant downstream provider’s requirements. Additional or refreshed information may be requested where existing information is insufficient, stale, expired or not accepted by the provider.
Additional information or verification may be required where a customer or transaction presents elevated risk, where required by a service provider, or where required by applicable law.
A customer’s successful identity verification does not guarantee that a transaction will be approved.
5. Sanctions and Restricted Parties
1Locol does not knowingly provide services for the purpose of circumventing applicable sanctions or other legal restrictions.
Customers and transactions may be screened against applicable sanctions, restricted-party, politically exposed person, and other relevant compliance databases.
Where a potential sanctions or restricted-party match is identified, 1Locol may:
- prevent or delay a transaction;
- restrict access to a Service;
- request additional information;
- conduct further review;
- refer the matter to an applicable regulated provider; or
- take any other action required by law.
6. Transaction Monitoring
Transactions and account activity may be subject to monitoring and financial-crime controls operated by 1Locol’s regulated service providers and other compliance partners.
1Locol reviews available transaction data, provider-generated risk signals, account activity and compliance information to identify activity that may require restriction, further review or escalation.
Monitoring and review may consider indicators including money laundering, terrorist financing, fraud, sanctions evasion, account takeover, unusual transaction patterns, abnormal velocity, unusual beneficiary activity and other financial-crime risks.
Controls may involve automated provider controls, third-party compliance tools, provider-generated risk signals and manual review.
1Locol may restrict, delay, reject or escalate activity that presents an unacceptable financial-crime risk or cannot reasonably be reconciled with the customer’s expected use of the Services.
7. Regulated Service Providers
1Locol may rely on regulated payment, wallet, custody, conversion, settlement, or payout providers to perform controls associated with the regulated financial services they provide.
Depending on the transaction route, such providers may independently perform:
- customer or transaction screening;
- transaction monitoring;
- sanctions and PEP checks;
- source-of-funds or source-of-wealth enquiries;
- payment and beneficiary verification;
- blockchain or wallet screening;
- local regulatory checks; and
- regulatory reporting.
These controls supplement rather than automatically replace 1Locol’s own policies and risk decisions.
Relevant KYC/compliance information or evidence may be shared with downstream regulated payment, banking, wallet/custody, settlement or payout providers where necessary for a service or payment corridor requested by the customer and permitted by applicable law. Disclosure is limited to information reasonably necessary for the recipient’s role, compliance obligations and provision of the requested service, consistent with our Privacy Policy.
1Locol maintains records of the provider, control, result, relevant evidence, policy or rule applied, and transaction state where appropriate to support auditability and compliance oversight.
8. Enhanced Due Diligence
Where elevated risk is identified, enhanced due diligence may be required.
This may include requesting additional information concerning:
- identity;
- address;
- occupation or business activity;
- purpose of a transaction;
- relationship with a beneficiary;
- source of funds;
- source of wealth; or
- supporting transaction documentation.
Access to certain services may be suspended or restricted until requested information has been satisfactorily reviewed.
9. Fraud and Abuse Prevention
Financial-crime controls operate alongside 1Locol’s fraud and security controls.
We may use information relating to:
- account history;
- devices;
- payment instruments;
- IP and network information;
- transaction behaviour;
- failed or repeated payment attempts;
- beneficiaries;
- chargebacks;
- refunds; and
- third-party fraud or risk signals.
We do not publicly disclose the precise thresholds, scoring logic, velocity limits, or detection rules used by our systems.
10. Suspicious Activity and Escalation
Activity that appears suspicious or inconsistent with expected customer behaviour may be escalated for review.
Depending on the circumstances, 1Locol may:
- request further information;
- delay or reject a transaction;
- restrict or suspend an account;
- refer the activity to an applicable regulated service provider;
- preserve relevant records;
- cooperate with law-enforcement or regulatory authorities; or
- take other action required or permitted by law.
Where a regulated provider has responsibility for filing a suspicious transaction or activity report relating to the financial service it provides, 1Locol will cooperate with that provider as appropriate.
Nothing in this Policy requires 1Locol to disclose whether a report, investigation, or regulatory referral has been made where such disclosure is prohibited by law.
11. Record Keeping
1Locol maintains records reasonably necessary to support:
- identity and compliance decisions;
- transaction monitoring;
- investigation and escalation;
- provider reconciliation;
- audit trails;
- fraud prevention; and
- legal or regulatory obligations.
Records may be retained for longer than an active customer relationship where required or permitted by law, regulation, contractual obligations, fraud-prevention requirements, or legitimate compliance needs.
12. Compliance Governance
Responsibility for 1Locol’s financial-crime framework is assigned internally to an appropriate compliance owner.
This includes oversight of:
- AML and financial-crime policies;
- risk assessment;
- third-party compliance providers;
- transaction-monitoring controls;
- escalations and investigations;
- sanctions controls;
- record keeping; and
- periodic review of the compliance framework.
1Locol does not use a statutory title such as Money Laundering Reporting Officer unless such a role has been formally established and is required or appropriate under applicable law.
13. Training and Internal Controls
Relevant personnel may receive training appropriate to their responsibilities concerning:
- financial-crime risks;
- suspicious activity;
- sanctions;
- identity verification;
- fraud;
- escalation procedures; and
- confidentiality obligations.
Access to compliance information is restricted according to role and business need.
14. Cooperation With Authorities and Partners
1Locol may cooperate with:
- regulated payment and financial service providers;
- telecommunications or connectivity providers where relevant;
- law-enforcement authorities;
- courts;
- regulators; and
- other competent authorities,
where required or permitted by applicable law.
We may also provide information necessary for a regulated provider to satisfy its own compliance obligations where such disclosure is lawful and consistent with our Privacy Policy.
15. Policy Review
1Locol reviews its AML and financial-crime controls periodically and may update them in response to:
- changes in applicable law or regulation;
- new products or services;
- new payment or settlement providers;
- changes in geographic coverage;
- identified financial-crime risks;
- incidents or investigations; or
- changes in industry standards and good practice.
This public Policy may be updated from time to time to reflect material changes to our compliance framework.
16. Contact
Questions regarding this Policy may be directed to:
1Locol Technologies LTD 69 The Junction The Crossings Lucan, Co. Dublin Ireland K78 T6W8
Compliance: compliance@1locol.com