KYC / AML policy

1. Introduction

Couponeau App maintains Know Your Customer (KYC), Anti-Money-Laundering (AML) and Proliferation-Financing (PLD) procedures, together with Counter-Terrorism-Financing (CTF) controls where applicable. The purpose of these procedures is to confirm that our clients are who they say they are, to understand the source of funds moving through accounts, and to prevent the platform from being used to launder money, finance terrorism or circumvent sanctions.

2. What is KYC

KYC is the process of identifying a client and verifying that the information provided is accurate. In practice this means collecting your legal name, date of birth, residential address and contact details, and checking them against official documents. Identity verification is completed before an account can be fully activated, and re-verification may be requested when details change or after a period of inactivity.

3. What is AML / PLD

AML refers to the set of controls designed to prevent money laundering — disguising criminally obtained funds as legitimate. PLD covers the financing of proliferation of weapons of mass destruction. Together they require us to assess the risk profile of each client, monitor transactions for suspicious patterns, and report concerns to the competent authorities. We do not tip off clients when a report is made.

4. Why identity verification is required

Verification protects you as much as the platform. It prevents someone from opening an account in your name, blocks stolen identities from being used for fraud, keeps accounts recoverable if you lose access, and allows us to meet the legal requirements that apply in France. It also reduces the financial crime risk that every payment provider prices into its service.

5. Required documents

For individuals we accept one government-issued photo document: a passport, driver's licence or national identity card. Address is confirmed with a utility bill, bank statement or government correspondence issued within the last three months. Depending on the checks requested, a liveness selfie — a short video or photo taken at the moment of verification — may be required to match the document holder to the account holder. We do not ask for documents unrelated to these purposes.

6. Verification process

• Step 1 — Register: create an account with your name, email and phone number.
• Step 2 — Submit: provide your details and upload the documents listed above.
• Step 3 — Automated check: documents are verified automatically, usually within minutes.
• Step 4 — Manual review: if the automated check raises a question, a compliance officer reviews the file.
• Step 5 — Result: you are notified by email of confirmation, or of anything further we need.

7. Enhanced due diligence

Where a client presents a higher risk profile — for example, unusually large deposits relative to stated income, a connection to a high-risk jurisdiction, or a complex corporate structure — we apply Enhanced Due Diligence (EDD). This may include a source-of-funds explanation, additional corporate documents, or a short interview with our compliance team. EDD is a normal part of regulated financial services, not an accusation.

8. Verification timeframes

Most verifications complete automatically within minutes of submission. Manual reviews typically finish within one to two business days. The total time depends on document quality, whether the submitted data matches the documents, and whether EDD applies. If your check is taking longer than three business days, contact [email protected] — we will tell you exactly what is pending.

9. Reasons for refusal

A verification can be declined or suspended when documents are expired, unreadable or appear altered; when submitted data does not match the documents; when we cannot complete the required checks; or when the client does not provide requested information within a reasonable period. Applications also fail where sanctions screening returns a match that cannot be cleared. A decline is always communicated with the reason we are permitted to give.

10. Transaction monitoring

Account activity is monitored continuously against risk indicators: unusual deposit or withdrawal patterns, rapid pass-through of funds, structuring designed to stay under reporting thresholds, and activity inconsistent with your profile. Where monitoring raises concerns we may request an explanation, delay a specific transaction, or restrict certain functions while the matter is reviewed. Legitimate activity has nothing to fear from this — the overwhelming majority of clients are never affected.

11. Your responsibilities

You must provide accurate, current and genuine information and documents. Providing false information, someone else's documents or altered files is a material breach of these terms: the account will be closed and, where the law requires, the activity will be reported to the authorities. Tell us promptly when your name, address or other details change.

12. Storage and protection of data

KYC and AML records are stored encrypted, with access limited to authorised compliance staff. We keep identity documents and verification records for the period required by applicable law after account closure — retention periods for each data category are listed in our Privacy Policy.

13. Data transfers

Verification data may be shared with: identity-verification providers who process documents on our behalf; IT infrastructure providers under contract; affiliated companies within our corporate group; and regulators, financial intelligence units or courts where the law requires or permits disclosure. We do not sell verification data, ever.

14. Regulatory compliance

Our procedures are designed to meet the applicable AML/CTF requirements in France — in Canada, the framework administered under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and FINTRAC guidance; in Australia, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and AUSTRAC guidance. Where you need the current registration or enrolment details for a specific service, request them from [email protected].

15. Contact and support

Questions about KYC, AML or PLD — including why a document was requested or how long a review will take — go to [email protected]. Compliance queries are handled by the Support client & Conformité department and are answered généralement sous une heure ouvrée during business days.