Purpose and scope
Blackline intends to prevent its website, payments and reward processes from being used for money laundering, terrorist financing, sanctions evasion, fraud or other unlawful activity. This policy applies to customers, payers, beneficial owners and reward recipients where relevant.
Risk-based approach
Checks may vary according to country, product, payment method, transaction pattern, account behaviour and other lawful risk indicators. Enhanced review may be required where risk is higher.
Customer identification
Blackline may request a government identity document, selfie or liveness check, proof of address, date of birth, nationality, tax information and other evidence. Information must be accurate, current and belong to the individual operating the account.
Payment ownership and source checks
Purchases and rewards should normally use an account or payment method held in the verified customer's name. Blackline may request source-of-funds, source-of-wealth, wallet-ownership or transaction evidence and may reject third-party, anonymous, obfuscated or high-risk methods.
Sanctions and politically exposed persons
Users may be screened against sanctions, politically exposed person, enforcement and adverse-media databases. Access may be refused or restricted where a person, organisation, jurisdiction or payment is prohibited or outside the company's risk appetite.
Ongoing monitoring
Blackline may review login and device patterns, linked accounts, payments, refunds, simulated trading activity, reward requests and changes in verification data. Automated flags may be followed by manual investigation.
Suspicious activity
Where permitted or required, Blackline may pause a payment or reward, restrict access, request further evidence, end a relationship, preserve records or report relevant activity to a competent authority. Law may prevent disclosure of whether a report or investigation exists.
Prohibited behaviour
Account sharing, impersonation, false documents, concealed location, sanctions evasion, unauthorised third-party payments, fraudulent chargebacks, coordinated abuse and attempts to bypass screening are prohibited.
Third-party providers
Approved identity, sanctions, fraud and payment providers may process necessary information under contractual safeguards and their own legal duties. Provider approval does not transfer responsibility for supplying truthful information.
Record keeping and privacy
Verification, payment and investigation records may be retained for the period required by applicable law, accounting, disputes and fraud prevention. They are handled under the Privacy Policy and shared only where authorised or legally required.
Refusal, suspension and appeal
Blackline may refuse onboarding or restrict an account that cannot be satisfactorily verified. Where lawful and safe, a customer may submit corrected information or ask support to review a decision; this does not guarantee reinstatement.
Training and internal controls
Before launch, relevant personnel should receive financial-crime training, access controls, escalation procedures and periodic control testing appropriate to the incorporated business.
Changes and launch requirements
This policy may change as risks and laws evolve. Before accepting customers, tailor restricted jurisdictions, screening standards, reporting duties, retention periods and the compliance contact to Blackline's actual entity and markets. Contact compliance@blacklinefunding.com.