Verification policy
Who we check, and what we refuse.
Our terms let us ask who you are, who you act for and what you will use the service for. This page sets out when we ask, what we check and what we refuse, before you pay.
When we ask
Before a product, a payment or a refund
The terms let us ask at any time. These are the moments our published policies name.
Before we enable a product or accept a payment
We may ask you to verify your identity, your organisation or your intended use before we enable a product or accept a payment.
Before we pay a refund
We may ask you to verify your identity before paying a refund. If you paid in cryptocurrency, we may ask you to confirm the address of the wallet you paid from or, if you paid from an exchange, to show us its withdrawal record.
When an automated check holds an order
Orders and payments pass through automated fraud and sanctions checks, which can hold an order or ask for verification.
Before you automate a trading account
Account automation on cryptocurrency and trading platforms needs a written note from us first, because the abuse rate there is high.
What we check
Sanctions, identity and intended use
Sanctions lists
We screen accounts against sanctions lists, for sanctions administered by the United States, the European Union, the United Kingdom and the United Nations.
Your identity and organisation
When we ask you to verify your identity or your organisation, Sumsub collects the identity document and other information it asks you for, and returns the result to us.
Your intended use
We may ask you to verify what you will use the service for. For security testing, we may ask to see your written permission to test the systems you target.
What we refuse
Where the answer is no
Sanctioned people and organisations
We do not provide the service to, or for the benefit of, any person or organisation that is the subject of sanctions administered by the United States, the European Union, the United Kingdom or the United Nations. You may not use it to route traffic on behalf of anyone who is.
Sanctioned countries and regions
We do not provide the service to anyone located, organised or ordinarily resident in a comprehensively sanctioned country or region, including Cuba, Iran, North Korea, Syria, and the Crimea, so-called Donetsk People’s Republic and so-called Luhansk People’s Republic regions of Ukraine.
Accounts that cannot be verified
We may restrict the service until verification is completed, and may decline or close an account where it cannot be completed.
Several accounts held to evade a limit
One person or organisation may not hold several accounts to evade a limit, a trial restriction or a suspension. Where we find the same identity behind more than one account, we may treat them as a single account.
Anyone under 18
The service is for business and professional use by people who are at least 18. If you open an account for an organisation, you must be authorised to bind it.
Review and appeal
Who reviews, and how to appeal
No account is closed by an automated check alone
An automated check can hold an order or ask for verification, but no account is closed on its result alone.
A person reviews an automated check on request
If an automated check affects you, you can ask for a person to review it at [email protected].
An enforcement appeal goes to a person
If we act on your account under the allowed-use policy, reply to the enforcement email. A person reads it and answers within two business days.
Records
How long we keep them, and who receives them
- Kept for
- 7 years after the account closes
- Shared with
- Sumsub, only when we ask you to verify
Questions
About this policy
- Will I be asked to verify before I can buy?
- You may be. The terms let us ask before we enable a product or accept a payment, and an automated fraud or sanctions check can hold an order or ask for verification.
- What does Sumsub receive?
- The identity document and other information it asks you for, and only when we ask you to verify. Sumsub returns the result to us.
- Can an automated check close my account?
- No. An automated check can hold an order or ask for verification, but no account is closed on its result alone. If one affects you, you can ask for a person to review it at [email protected].
- How long do you keep verification records?
- Verification and sanctions-screening records are kept for 7 years after the account closes.
Questions about a check?
Ask us before you buy, or read the clause of the terms this page restates.
This policy sits alongside our terms of service and privacy policy. Where they and this page disagree, the terms apply.