Legal

AML and sanctions policy

Poly Syncer is non-custodial — we never hold user funds — but we still screen wallets against international sanctions lists and block service to restricted jurisdictions.

Last reviewed · Poly Syncer legal review

Template notice. This document is provided for transparency and is not a substitute for legal counsel. Poly Syncer is non-custodial and is not a money transmitter. The controls below are implemented voluntarily, in addition to any obligations that may apply, to keep the service from being used by sanctioned actors or in restricted jurisdictions.

Anti-money-laundering (AML) and sanctions controls usually focus on custodial intermediaries — exchanges, brokers, and wallets that hold customer funds. Poly Syncer is not one of those. The service never takes custody, never holds private keys, and never processes a deposit or a withdrawal. Even so, providing infrastructure that touches public blockchains makes basic screening prudent. This policy describes what Poly Syncer screens, what it blocks, and how to report a concern.

1. Sanctions screening

When a wallet is connected for the first time, the address and any commonly linked addresses are screened against the following lists:

  1. The Specially Designated Nationals (SDN) and Consolidated Sanctions Lists maintained by the United States Office of Foreign Assets Control (OFAC).
  2. The European Union Consolidated Financial Sanctions List.
  3. The United Kingdom Office of Financial Sanctions Implementation (OFSI / HM Treasury) Consolidated List.
  4. The United Nations Security Council Consolidated Sanctions List.

Lists are refreshed at least daily from the original publishers. If a connected wallet, or a wallet that has interacted with the connected wallet through known mixing or laundering patterns, matches any of these lists, the connection is rejected and the user is shown a generic refusal message. Poly Syncer does not unblock sanctioned wallets and does not engage in correspondence about the basis of a refusal.

Screening is repeated periodically against the most recent list versions. A wallet that was clean at connection but is later added to a list will be disconnected at the next screening cycle and any active EIP-712 authorizations will be ignored by the listener.

2. Geographic restrictions

Poly Syncer does not provide service to users located in, ordinarily resident in, or accessing the service from the jurisdictions listed below. The list reflects a combination of comprehensive sanctions, prediction-market legality, and operator caution. The list may change without notice as conditions evolve.

  1. United States of America (placeholder pending jurisdiction-specific review; users should not rely on availability).
  2. Democratic People's Republic of Korea (North Korea).
  3. Islamic Republic of Iran.
  4. Syrian Arab Republic.
  5. Republic of Cuba.
  6. The Crimea region of Ukraine.
  7. The so-called Donetsk People's Republic and Luhansk People's Republic regions of Ukraine.
  8. The Russian Federation.
  9. The Republic of Belarus.
  10. The Republic of the Sudan and South Sudan.

Geographic restriction is enforced through a combination of IP-based geolocation at the edge layer and a self-attestation step at wallet connection. Use of a virtual private network, proxy, or other circumvention technology to mask location is a breach of the terms of service and may result in immediate termination.

3. Suspicious activity reporting

Poly Syncer monitors for behavioural patterns that are characteristic of attempted laundering or sanctions evasion through copy-trading infrastructure. These include, but are not limited to:

  1. Wallets that connect, sign a single high-value authorization, and disconnect, in a way that is inconsistent with copy-trading use.
  2. Networks of related wallets that copy each other in a pattern designed to fragment volume.
  3. Repeated attempts to connect from IP ranges associated with restricted jurisdictions.
  4. Patterns of activity flagged by external blockchain-analytics providers.

Where the activity rises above a credible suspicion threshold, the relevant wallet is disabled and a record is preserved for possible reporting to competent authorities, in line with applicable law in the jurisdiction in which the operator is incorporated. Poly Syncer will cooperate with lawful requests from competent authorities, while limiting disclosure to what is strictly required and lawfully compelled.

4. Record-keeping

Records kept for AML and sanctions purposes are intentionally minimal:

  1. The connected wallet address.
  2. The result and timestamp of the most recent sanctions screening for that address.
  3. The country code returned by IP-based geolocation at the moment of connection.
  4. Where a suspicion has been raised and recorded, a short text note describing the trigger and the action taken.

These records are retained for the period required by applicable law in the jurisdiction of the operator, and are otherwise deleted. No KYC documents are collected, because none are requested. The broader privacy stance is described in the privacy policy.

5. Reporting concerns

If you believe a wallet is using Poly Syncer to evade sanctions, launder funds, or otherwise abuse the service, please report it. Reports can be sent to [email protected]. Useful information to include:

  1. The wallet address you are reporting.
  2. The basis of your concern, with on-chain references where possible.
  3. Whether you are a competent authority making a formal request, or a member of the public sharing information.

Reports are reviewed in the order received. Poly Syncer will not confirm or deny the existence of an investigation, the identity of an account holder, or the substance of any record kept under section 4 above, except to the extent required by law.

For unrelated questions, use the general contact page. For risk warnings about prediction-market trading, see the risk disclosure.