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AML / KYC Policy

Public summary of our anti-money-laundering and counter-terrorist-financing framework.

Effective 1 January 2026 · Last reviewed June 2026

1. Commitment

Eurosia Systems OÜ operates a risk-based AML/CFT programme aligned with the EU 6th AMLD, MiCA, the FATF Travel Rule, and Estonian national law. We are supervised by the Estonian Financial Intelligence Unit (FIU).

2. Customer due diligence (KYC)

  • Identity verification using government-issued IDs and biometric liveness.
  • Address verification for higher-risk products.
  • Beneficial ownership verification for business accounts.
  • PEP and sanctions screening at onboarding and continuously thereafter.
  • Enhanced due diligence for high-risk geographies, PEPs, and large transactions.

3. Transaction monitoring

All transactions are scored in real time using rules and machine- learning models for typologies including layering, smurfing, structured deposits, and blockchain-specific risks. Suspicious activity is escalated to our MLRO and reported to the Financial Intelligence Unit as required by law.

4. Travel Rule

Originator and beneficiary information is exchanged with counterparty VASPs in line with the EU Transfer of Funds Regulation (Regulation (EU) 2023/1113) and TRP (Travel Rule Protocol).

5. Blockchain analytics

Crypto-asset deposits and withdrawals are screened against blockchain analytics providers (Chainalysis, TRM Labs) to identify exposure to sanctioned addresses, ransomware, mixers and darknet markets.

6. Record keeping

AML/KYC records are kept for at least five years after the end of a business relationship.

7. Training and governance

All staff complete annual AML/CFT training. The programme is overseen by the Money Laundering Reporting Officer (MLRO) and reviewed annually by the Board.

8. Reporting concerns

Suspicious activity or compliance concerns can be reported in confidence to info@eurosiapay.com. Whistle-blowers are protected under EU Directive 2019/1937.


If you have questions about this document, contact info@eurosiapay.com or write to Eurosia Systems OÜ, Tornimäe tn 7, 10145 Tallinn, Estonia.