Acceptable Use Policy

About this policy

This Acceptable Use Policy (the “AUP”) sets out what you can and can't do when you use Align Payments Ltd. (“Align,” “we,” or “us”) to send, receive, hold, exchange, or process money or virtual currency.

Align is a Canadian Money Services Business registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). We are required by Canadian law to know who our clients are, understand what they use our services for, monitor transactions, and report certain activities to the authorities. This AUP explains how that works in practice from your side.

It applies to every person and business that uses Align's services, whether they access us directly, through a partner app or website built on our platform, or via our APIs.

The short version

• •We're built for legitimate businesses and individuals making real payments and virtual currency transactions.
• •Some activities are completely off-limits — we list them below.
• •Some activities are allowed but require extra checks before we'll work with you.
• •If something looks unusual, we may pause activity, ask for more information, or end the relationship.

How we work with you

What we'll ask you for

Before you can use Align, and from time to time afterwards, we'll ask you to verify your identity and tell us about your activity. What we need depends on whether you're an individual or a business, what you do, and how you use us — and we'll tell you exactly what's required during onboarding. This isn't optional: Canadian law requires it, and we can't onboard or continue serving you without it.

Keeping your information current

You agree to keep your information up to date and to tell us promptly when something material changes — for example, a new beneficial owner, a change in directors, a new line of business, a new operating jurisdiction, or a significant change in how you use Align, such as new corridors or counterparties, or transaction sizes or volumes well outside what you told us to expect. If we send you a periodic review request, please respond by the deadline. If we can't keep your information current, we may have to suspend or end your relationship with us.

Activities we don't allow

These activities are off-limits on Align. If you're involved in any of them, we won't onboard you, and if we discover them after you've onboarded, we'll end the relationship. In some cases we're also required to freeze funds.

Why these are off-limits

Some are illegal. Some carry such high money-laundering or terrorist-financing risk that we've decided as a matter of policy not to touch them. Some involve sanctions regimes we have to comply with. The list isn't arbitrary — it reflects Canadian law, international standards (FATF, FINTRAC, Wolfsberg Group), and the way Align has chosen to operate.

Countries we can't serve

We can't open or maintain a relationship with anyone — individual or business — who lives in, is incorporated in, operates from, or routes transactions through any of the following countries. This applies to you, to anyone who owns or controls your business, and to people or businesses you transact with.

Example: If you're a Canadian business but one of your suppliers or beneficiaries is based in a prohibited country, we won't be able to process that payment. Please use a different provider for that transaction, or arrange your flow so Align isn't involved.

Other high-risk countries

Some countries aren't completely off-limits but carry elevated risk, so they trigger extra checks before and during our relationship with you. If you, your business, your owners, or your transactions touch a country we treat as higher-risk, expect us to ask for more information, to take longer to approve activity, and to keep a closer watch on related activity. The countries this applies to can change as international standards and sanctions measures change.

Industries we can serve, with extra checks

Some industries are legal and legitimate but carry elevated money-laundering, terrorist-financing, or fraud risk. We can work with you in many of these areas, but only after enhanced due diligence. That generally means more detailed questions and documentation, checks on your source of funds (and, where relevant, source of wealth), and in some cases conditions or limits on how you can use Align.

This isn't an exhaustive list — we may apply enhanced checks to other activities based on our own assessment. Being in one of these categories doesn't mean you'll be declined; it means our process may take longer and ask more of you.

Financial institutions: own funds only

• •If you're a financial institution — for example an MSB, money transmitter, FX or remittance provider, PSP or payment facilitator, or VASP — we may be able to onboard you after enhanced due diligence and additional approval, but only to move your own operational funds: paying your own suppliers, invoices, and payroll, and making your own treasury movements.
• •What we won't support is running your own customers' activity through Align. You can't use your Align relationship to provide accounts, wallets, payments, settlement, or custody to your customers, to hold, pool, or move your customers' funds, or to nest their transactions behind your account. That is the prohibited “nested” activity described under “Activities we don't allow” and in the businesses section below, and it applies whether or not you are licensed or registered.

Rules for everyone

Be truthful with us

Everything you tell us during onboarding and afterwards has to be accurate and complete. That means real names, real addresses, real ownership information, real business activity, real source of funds. Submitting false, forged, or altered documents — or repeatedly failing identity verification with different identities — is grounds for immediate termination.

Use Align for your own activity

Your Align account or service relationship is for you. If you're an individual, you can't let someone else use your account or transact through it for their benefit. If you're a business, you can't let an undisclosed third party route transactions through your Align facility.

If you're acting for someone else in a particular transaction (for example, you're paying on behalf of an employer, or your business is moving funds on behalf of a client of yours), you have to tell us in advance. Canadian law requires us to identify that third party, and we won't process the transaction until we have the information we need.

You also can't use Align as a pass-through or flow-through layer for funds. That means moving money or virtual currency in and straight back out to put distance between it and its origin, or routing it through extra accounts, entities, or wallets so that it's harder to see who the funds really belong to or where they're really going. If we can't see the true source, the true destination, and the real parties involved, we won't process the activity.

No physical cash

Align is a fully digital service. We don't accept physical cash deposits and we don't pay out in cash. If you receive funds intended for your Align account in cash form (for example, someone hands you cash to top up your account), please decline — we can't process those funds through us.

No anonymous or fake-name accounts

Every account is opened in the real legal name of the real person or business behind it. We don't open or maintain accounts under aliases, pseudonyms, fictitious names, or for unidentified clients. The only names that appear on your account should be your own.

Provide information we ask for

From time to time we'll need to ask you for additional information — about a particular transaction, about a counterparty, about a change in your activity, or as part of a routine periodic review. You agree to respond reasonably promptly. If you don't, we may pause your activity until you do, and ultimately may have to end the relationship.

Travel Rule information for transfers

For certain wire, electronic, and virtual currency transfers above regulatory thresholds, we're required to collect and pass on prescribed identifying information about both the sender and the recipient. If you can't or won't provide complete and accurate information, we may not be able to send the transfer, or it may be returned.

Don't try to evade our rules or the law

Don't take steps designed to get around our controls or the law, or to disguise what's really happening with your funds or who's involved. Activity like this is a red flag — if we see it, we may restrict, suspend, or close your account, and take any further steps our legal obligations require.

Rules for virtual currency users

If you exchange, send, or receive virtual currency through Align, the following rules apply on top of everything else in this policy.

Wallets we won't transact with

We screen the wallet addresses we send to and receive from, and we won't transact with wallets linked to sanctions, illicit activity, or other high-risk sources, or holding assets we don't support. Where a wallet presents this kind of risk, we may decline or block the transfer.

Unhosted (self-custody) wallets

You can send to and receive from self-custody wallets, subject to verification. Before processing a transfer, we may ask you for information about the wallet or the parties involved. If a wallet presents a high risk, or you don't provide the information we need, we may block transfers to or from it.

No custody or exchange on behalf of others

Align's virtual currency services are for your own funds and your own activity. You can't use them to hold, exchange, or transfer virtual currency on behalf of your customers or any other third party, to pool client funds in a shared or omnibus wallet, or to run anything that operates like a custodial wallet, exchange, or VASP on top of our rails. This is prohibited under “Activities we don't allow” above — if we identify it, we'll review and end the relationship, and we may be required to take further steps to meet our legal obligations.

Don't try to hide what you're doing

Activity designed to obscure the origin, destination, or ownership of virtual currency, or to break the traceability of your transactions, will be detected and treated as suspicious. If you have a legitimate operational reason for activity that looks like this, tell us in advance — otherwise expect your transactions to be paused for review.

Additional rules for businesses and developer partners

Nested relationships

Your Align account and API access are for your own business. You can't use them to nest other people's financial activity behind your relationship with us. In particular, you can't:

• •act as a payment intermediary for other businesses — for example, by facilitating, aggregating, or passing through payments, transfers, or settlements that belong to them or to their customers;
• •run a payment-facilitation or payment-aggregation model on top of Align;
• •provide accounts, wallets, sub-accounts, or pooled balances to another financial institution, money services business, or payment service provider — whether or not that business is registered, or is required to be registered, anywhere it operates; or
• •hold, exchange, or move virtual currency on behalf of your customers or any other third party, or operate sub-accounts or pooled (omnibus) wallets that hold funds or virtual currency for others.

Models like these effectively turn your account with us into financial services that you are providing to other people. Depending on what you're doing, they may also mean you are operating as a money services business, payment service provider, or virtual asset service provider that needs its own registration. This falls outside what Align serves.

If your business model already includes any of these activities, or changes to include them, you must tell us before the activity starts. We will review the relationship and, in most cases, end it.

Marketplace operators with seller payouts: contact us before onboarding so we can confirm whether your specific model fits.

Refunds, chargebacks, and reversals

Refunds need to go back to the original payment source. Refunds to unrelated cards, accounts, or wallets — “refund laundering” — are prohibited. Refund or chargeback activity that's inconsistent with normal commercial behaviour may result in review, settlement holds, reserves, or termination.

API and integration use

Use our APIs as documented and as agreed in your Developer Agreement. Abnormal or abusive API activity may result in rate limiting, suspension, or termination.

What we'll do if there's a problem

If your activity doesn't match what you've told us, or raises money-laundering, terrorist-financing, sanctions, or fraud concerns, we may take action — including asking you for more information, holding, restricting, or pausing some or all of your activity, freezing funds, or ending the relationship. We may take more than one of these steps, and where the law requires, we may act immediately and without prior notice.

Most of the time we'll simply ask you for more information, and responding fully and promptly is the fastest way to resolve things — routine requests aren't accusations, they're how a regulated business works.

Freeze funds

We will freeze funds where we are legally required to do so.

End the relationship

Where a concern can't be resolved, or where activity falls outside our risk appetite or this AUP, we may end the relationship. Where the law permits, we'll explain what's happening and return any funds you're entitled to.

Your part of the deal

Tell us when something changes

Email us or use the in-app reporting tool to let us know about: a new beneficial owner, a new line of business, a new operating jurisdiction, a change of address, a change of directors or signatories, a change in expected transaction profile, or anything else material to how you use us.

Tell us if something feels wrong

If you suspect your account has been compromised, if someone has approached you about using your account for someone else's transactions, if you've spotted a phishing attempt that uses Align's name, or if you've noticed activity on your account you don't recognize — contact us immediately.

Disagree with a decision?

If you think a decision we've made is wrong, you can request a review by emailing us. Please include any context that helps us understand the situation. We'll respond within a reasonable timeframe. Some decisions — those mandated by law or by sanctions obligations — can't be appealed at Align's level, but we'll tell you that where we're permitted to.

Changes to this policy

We update this AUP from time to time — when laws change, when sanctions lists change, when we identify new risks, or when we adjust our own risk appetite. The current version is always the one published on our website, identified by the effective date at the top. Continued use of Align after the effective date of a change means you accept the updated version.

Getting in touch

For any questions about this policy, or to report something to us, email compliance@alignlabs.dev.