AML and KYC policy (summary)
How Twirrle prevents money laundering and sanctions evasion: verification, screening, monitoring and the deposit turnover rule.
Principles
We do not accept money from crime, terrorism financing or sanctioned persons, and we do not allow the Service to be used to move or clean money. This summary describes the controls that apply to the real-money book; the practice book involves no money.
Verification (KYC)
- We may ask you to verify your identity, address, age and the source of your funds at any time — typically before the first withdrawal, when amounts reach internal thresholds or when activity looks unusual.
- Until verification is complete we may hold withdrawals or limit the account.
- We keep verification records for as long as the law requires.
Sanctions and wallet screening
- Users and deposit and withdrawal addresses are checked against sanctions lists (including the U.S. OFAC list of sanctioned digital-currency addresses, refreshed daily) and blockchain-risk sources. Deposits from a listed address are not credited; withdrawals to a listed address are refused.
- Funds from high-risk or sanctioned sources are held and may be reported or returned as the law requires.
- The real-money book is available only in allowed regions; access from other regions is blocked.
Deposit turnover rule
A deposit must be traded through once — positions opened worth at least the deposited amount — before it can be withdrawn. This stops the Service from being used as a pass-through for funds. If you no longer want to trade, ask Support for a refund of the untraded deposit (category Withdrawal → “Refund a deposit I have not traded”); after our checks it is sent to an address you control that you give Support, less the network fee. There is no automatic return to the sending address.
Monitoring and reporting
We monitor activity for patterns such as many accounts per person, collusion, opposite positions across accounts, rapid in-and-out transfers or structuring. We may freeze balances, close accounts and report suspicious activity to the competent authorities without telling you if the law forbids it.
Your own funds only
Deposits must come from wallets you control and withdrawals go to addresses you control. A new withdrawal address has a cool-down before it can be used.