AML & Custody Policy
How customer funds are held, verified on-chain, and supervised — and how we prevent abuse.
Last updated: 2026-04-18
1. How the pass works
When a buyer purchases a TonPass Gift Card, the underlying USDT is deposited into the TonPass Master Wallet and earmarked 1:1 to that pass. Funds stay in the Master Wallet until the recipient redeems.
TonPass does not trade, lend, re-hypothecate, or invest the balance. The pass is simply a claim against a specific slot of USDT inside our own wallet.
TonPass earns a fee for issuance, fulfillment, and redemption only. The principal always belongs to the pass holder.
2. On-chain transparency
The TonPass Master Wallet is a published on-chain address. Anyone can read its balance and transaction history in real time, from any block explorer.
Total outstanding pass liability (sum of all unredeemed passes) is published and updated continuously. Master Wallet balance must cover total outstanding liability at all times — this is the 1:1 reserve guarantee.
Every redemption is an on-chain transfer from the Master Wallet to the recipient's TonPass Wallet, with a public transaction hash. Reserves cannot be silently drawn down — every outflow is visible.
3. Corporate governance & oversight
TonPass operates under a registered corporate entity with a compliance officer, external auditor, and designated AML reporting officer.
Quarterly proof-of-reserves attestations are published, comparing the Master Wallet on-chain balance to outstanding pass liability.
The governance entity is the party responsible for AML, sanctions screening, customer identification, and statutory reporting — not the pass holder, not the recipient.
4. Verification tiers
Under $300 per transaction: email verification only.
$300 – $1,000: email + phone verification.
Over $1,000: KYC Level 2 — government ID, selfie liveness, and sanctions screening.
Cumulative annual limits apply. Crossing a tier triggers step-up verification automatically before the next pass can be purchased or redeemed.
5. Sanctions & restricted regions
All buyers and recipients are screened against the UN, OFAC, EU, and UK sanctions lists at registration, before each purchase, and before each redemption payout.
Passes may not be purchased by, or redeemed into, wallets associated with sanctioned jurisdictions, designated persons, or politically exposed persons without enhanced due diligence.
6. Transaction monitoring
Purchases, redemptions, and referral payouts are monitored in real time for structuring, rapid cash-out, multi-account behavior, fraud patterns, and other known typologies.
Suspicious activity is frozen and reviewed by our compliance team. Confirmed suspicious activity is reported to the statutory authorities within required deadlines.
7. Record keeping
Pass-issuance records, KYC documents, redemption logs, and communication logs are retained for 5 years after the end of the business relationship, in line with applicable regulatory requirements.
8. Referral program controls
Self-referral is blocked via device, IP, and email heuristics. Referral payouts are subject to clawback if the underlying pass purchase is refunded, reversed, or flagged.
Maximum referral earnings per wallet: $5,000 per calendar month.