Legal & Compliance

AML/KYC Policy

Our commitment to maintaining the highest standards of Anti-Money Laundering, Counter-Terrorism Financing, and Know Your Customer compliance.

Introduction

At Sparq, we are fully committed to maintaining the highest standards of Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Know Your Customer (KYC) compliance. Our policy aligns with the guidelines issued by the Financial Action Task Force (FATF) and other major financial regulators.

We aim to provide secure, legal, and compliant crypto card services while balancing the privacy rights of our users in decentralized finance (DeFi) ecosystems.

1. Scope of Policy

This policy applies to all users, partners, service providers, and activities related to:

  • Crypto deposits (BTC, ETH, USDT, etc.)
  • Card top-ups and withdrawals
  • Virtual and physical card issuance
  • On-chain wallet transactions
  • Platform usage, including affiliate rewards
2. KYC (Know Your Customer) Requirements

2.1 When KYC is Required

We require identity verification in the following cases:

  • Card issuance in regulated jurisdictions
  • Exceeding spending or deposit limits
  • Triggering suspicious activity alerts
  • Requesting card replacement or cash withdrawal
  • Regulatory changes in your country

2.2 What We Collect

We may request the following data:

  • Government-issued ID or passport
  • Proof of address (utility bill, lease, etc.)
  • Selfie with document (for liveness check)
  • (Optional) Source of crypto funds in high-risk cases

2.3 Verification Process

• KYC is conducted via licensed third-party verification providers

• Identity checks are processed in minutes via encrypted systems

• Manual review may be required in some jurisdictions

3. AML (Anti-Money Laundering) Controls

3.1 Crypto Transaction Monitoring

We use automated tools like Chainalysis, Elliptic, or TRM Labs to assess wallet behavior and transaction history. We flag:

  • Addresses linked to sanctioned entities
  • Funds traced to mixers, tumblers, or darknet markets
  • Transactions from high-risk jurisdictions

3.2 Enhanced Due Diligence (EDD)

EDD is triggered when:

  • Deposits exceed legal thresholds
  • Wallets are flagged as "high-risk"
  • Card behavior appears suspicious
  • Funds originate from anonymizing tools (e.g. Tornado Cash)

In these cases, we may:

  • Request more documents (proof of source of funds)
  • Temporarily suspend or limit account functionality
  • Deny service if compliance cannot be confirmed

3.3 Sanctions and Blacklists

We comply with international sanctions lists including:

OFACEU Sanctions ListUN SanctionsUK HM Treasury

Users from sanctioned countries or found on blacklists will be denied access immediately.

4. Data Storage & Privacy

All KYC/AML data is:

  • Encrypted (AES-256 or stronger)
  • Stored on GDPR-compliant servers
  • Accessible only to authorized compliance personnel

We do not sell or share your identity data with marketers.

5. Reporting Obligations

Where required, we will file:

  • Suspicious Activity Reports (SARs)
  • Transaction Threshold Reports (TTRs)
  • Regulatory reports to card issuers and compliance partners

We may not notify the user when such reports are submitted, as per global AML best practices.

6. Your Rights

You may:

  • Request a copy of the data we hold about you
  • Request correction or update of your KYC info
  • Request deletion (subject to legal retention limits)
  • Appeal decisions made based on AML/KYC risk scoring
7. Updates

This policy is updated regularly to reflect new crypto regulations and risk factors. Check back often or subscribe to updates.

Questions About Our AML/KYC Policy?

Our compliance team is here to help you understand our policies and procedures.