Sanctions, verification and financial crime
Where we can do business, who we can pay, and what we may ask you to prove.
AESHA Technology Services Limited · Last revised 7 October 2026 · All legal documents
This policy applies to every account and to every payment in or out. It sits on top of the terms of service and alongside the acceptable use policy, which covers traffic quality and fraud. Breaking this one is grounds for suspension without notice, and for refusing a payout.
1. Where we can do business
AESHA Technology Services Limited (CRN 210193), Seychelles is bound by the sanctions and export-control regimes that apply to it and to the payment providers it uses. Those providers include institutions in the European Economic Area and the United States, so their rules reach every transfer we make on your behalf.
You may not open or hold an account, and we may not pay you, if you:
- are resident in, located in, or organised under the laws of a country or territory subject to comprehensive sanctions or an asset freeze by the United Nations, the European Union, the United Kingdom or the United States;
- are named on, or owned or controlled by a person named on, a sanctions or terrorist-financing list maintained by any of those authorities;
- are acting for the benefit of any such person, however the arrangement is described; or
- would cause us or a payment provider to breach an applicable law by transacting with you.
We do not publish a country list here, and deliberately so: a list in a document goes stale the week it is written, and a stale list is a promise we would be breaking without noticing. The designations above are the authoritative source, and they change.
What we actually do. We are not a bank and we do not run automated screening against those lists. We act on what we become aware of — from a payment provider refusing a transfer, from a notice, from the address and identity details on your own account, or from a review we carry out ourselves. When something puts a restriction in question we may ask you to evidence otherwise, and we may hold a payout while we do. If you become subject to a restriction, tell us; continuing to use the account is itself a breach.
2. Verifying who you are
We collect a beneficiary name, a full address and a country before we can pay you, because a bank rejects a transfer that is missing any of them. That is the minimum. We may ask for more, and this section is the basis on which we do.
We may require, before or after a payout is requested:
- a government-issued photo identity document, for an individual;
- certificate of incorporation, registered address and evidence of who owns or controls the company, for a business;
- evidence that the payout destination belongs to the account holder;
- a tax identifier or VAT number, where one applies to the payment; and
- an explanation of the traffic behind unusual earnings, with the records to support it.
Accounts are live immediately and this does not change that. You can integrate and start earning without sending us a document. Verification is a condition of being paid, not of using the platform, and we would rather ask at the point money moves than put a queue in front of a placement.
Advertisers paying by card or PayPal verify their identity first. Those are the two ways to pay us that the payer can later dispute, so before either is available we ask for an identity check through Didit: a photo of an identity document and a selfie. Until it is approved, card and PayPal are unavailable; crypto and bank transfer are not affected.
A payout can be held pending verification. If we ask for something and do not get it, the payout stays unpaid and the balance stays yours — we do not confiscate a balance for an unanswered request. What we cannot do is send money we are not satisfied we may lawfully send. Where a request is triggered by something specific, we will say what.
3. Money laundering and terrorist financing
The platform is not a payment service, a wallet or an exchange, and several things follow from that by design rather than by policy:
- You cannot deposit money and take it back out. A publisher balance can only be created by conversions we recorded. There is no route from a payment in to a payout out.
- An advertiser balance is spent, not withdrawn. Unspent funds are refundable only to the original payment source, and only as described in the advertiser agreement.
- We pay the account holder and nobody else. We do not send a payout to a third party, to an account in another name, or split one between destinations.
- We do not convert currency as a service. A crypto payout is a way of settling what you earned, not an exchange.
We will refuse or reverse a transaction, and suspend an account, where we have reasonable grounds to suspect money laundering, terrorist financing, sanctions evasion or fraud. Where the law requires us to report a suspicion and prohibits telling you, we will comply with both, which means there are circumstances in which we cannot explain a refusal. That is a narrow exception to how we otherwise work, and it is stated here rather than discovered.
4. Fraud
Traffic quality, fabricated completions and what happens to a balance when they are found are covered in the acceptable use policy, which describes the checks the platform actually runs and the order in which we escalate. This policy adds one thing: where fraud also raises a financial-crime concern, §3 applies as well, and the reporting exception in it can apply.
5. What we keep, and for how long
Identity documents are held for as long as the account is open and for five years after the last payment, which is the retention period the anti-money-laundering rules of the payment providers we use expect. They are held for that purpose only: they are never used for marketing, never sent to an advertising network, and never shown to a publisher or an advertiser. What each third party receives is listed in subprocessors, and your rights over the data are in the privacy policy.
6. Questions, and getting a decision looked at again
If a payout is held, a verification request is unclear, or you think a restriction has been applied to you in error, write to [email protected]. Except where §3 prevents it, we will tell you what we are looking at and look again at the records behind the decision.