AML/CFT & Sanctions

1. Our posture

Ladumapay is a software interface operated by Wealth Boutique OÜ. Wealth Boutique holds no financial licences, does not hold user funds, does not hold user keys, does not take custody of crypto assets, and does not carry out regulated financial services on its own account. See our Availability & Providers page for the full statement.

For that reason, Wealth Boutique is not itself the entity that performs customer due diligence, transaction monitoring, or sanctions clearance on financial transactions. Those functions sit with the third-party regulated providers who deliver the underlying services — most importantly Entry (technology provider) and Nimbus LLC dba Third National (Puerto Rico Money Transmitter, OCFI licence TM-0207, NMLS ID 2612780) for the card programme.

What Wealth Boutique does apply, on its own account, is described below: interface-level sanctions and geofencing, cooperation with law enforcement, and no-tolerance rules on abuse of the interface.

2. Sanctions screening and geofencing

At the interface layer we apply hard geofencing and sanctions checks:

• Country block on registration. People located in or resident of the jurisdictions listed in section 4 cannot register or use the interface, regardless of the provider's own posture.
• Country-selection block. The country picker at sign-up refuses the same jurisdictions.
• Location check. Registration is refused when the visitor's network-level location resolves to a blocked jurisdiction, including the occupied Ukrainian regions listed in section 4. No IP address is stored.
• Email-domain check. Registration refuses email addresses on the country-code top-level domain of a blocked jurisdiction.
• Phone-number check. Registration refuses phone numbers whose country calling code maps unambiguously to a blocked jurisdiction. Where a country calling code is shared across many countries (e.g. +1, which covers the United States, Canada and Caribbean countries under the North American Numbering Plan), we do not block on the calling code alone — that would over-block countries that are not on the list. In those cases the country block is applied at ISO level only (country selection, KYC country, address country).
• Sanctions. Registration and use are refused for any person on current EU, UN, OFAC, UK or FATF sanctions or high-risk lists. The interface additionally refuses registration for any country that is subject to comprehensive sanctions under EU, UN or OFAC programmes at the time of registration.

Providers run their own KYC/AML/sanctions checks on top of ours, using their regulated programmes and their own screening data. Those checks can independently decline, suspend, or terminate service to a person who passes our interface-level checks.

3. Customer due diligence is performed by the providers

Wealth Boutique does not collect KYC documents, identity documents, proof of address, or source-of-funds evidence. When a third-party provider requires those (typically for the card programme), the user completes onboarding directly with that provider under that provider's regulated CDD programme. That provider is the obliged entity for AML purposes with respect to the financial transactions it settles.

For self-custodial wallets and cross-chain routing, no account is opened with Wealth Boutique — the user's wallet is a self-custodial address on public infrastructure.

4. Blocked jurisdictions

Cuba, Iran, North Korea, Syria, Russia, Belarus, the occupied Ukrainian regions of Crimea, Sevastopol, Donetsk and Luhansk, Egypt, Morocco, Algeria, Tunisia, Libya, Ethiopia, Sudan, South Sudan, United States of America — plus any country appearing on current EU, UN, OFAC, UK or FATF sanctions or high-risk lists.

This list is the twin of the enforcement code in the interface and is kept in sync with it. The block applies to registration and use of the Ladumapay interface. Card and wallet providers may block additional countries under their own regulatory posture; where a provider blocks a country that we do not, that provider's block still applies.

The block above is not exhaustive of the world's regulatory picture. Additional restrictions may apply to individual users based on residence, nationality, PEP status, sanctions exposure, or provider policy. Access can be refused or withdrawn at any time.

5. Suspicious activity and cooperation with law enforcement

If Wealth Boutique becomes aware of activity through the interface that gives reasonable grounds to suspect money laundering, terrorism financing, sanctions evasion, fraud, or other serious crime, we may — without notice to the user — restrict or terminate the user's access to the interface, report to the appropriate authorities in Estonia or the relevant jurisdiction, and cooperate with law-enforcement or regulator requests where legally required.

Providers separately operate their own suspicious-activity reporting under their own regulatory obligations.

Nothing in this page limits any lawful obligation Wealth Boutique may have to disclose information to a regulator, court, or law-enforcement agency, or overrides a "tipping-off" restriction under applicable law.

6. No advice

This page describes the interface-level posture. It is not legal, tax or financial advice. It does not create obligations owed to individual users beyond those set by law and by our Terms of Service.

7. Contact

Sanctions and AML questions: legal@ladumapay.com

Suspicious-activity notifications: legal@ladumapay.com with subject "AML"

Post: Wealth Boutique OÜ, Uus-Sadama tn 21-207, 10120 Tallinn, Estonia