1. Purpose
This policy describes how the Enralo service (the “Service”) prevents the use of its software for money laundering, terrorist financing and the circumvention of sanctions.
2. Nature of the service
The Service sells a software service: it covers the resource cost of transactions in the TRON network. The Service does not hold client crypto assets in custody, does not exchange crypto for fiat currency, and does not transfer client funds between addresses.
This limits the risk profile but does not remove the obligation to monitor for abuse.
3. Risk-based approach
Controls are applied proportionally to the risk of the client and of the operation: payment volume, payment method, the counterparty addresses involved, and the jurisdiction of the client.
Elevated-risk cases are escalated to a manual review before the service continues.
4. Screening and monitoring
Public TRON addresses submitted in orders may be screened against sanctions and high-risk address lists.
Order flow is monitored automatically for patterns typical of abuse: structuring, unusual volume growth, and repeated use of addresses linked to reported incidents.
5. Client identification
Retail users are identified by their Telegram account. Business clients provide contact and, where required, corporate details during onboarding.
The Service may request additional identification documents when volume thresholds are exceeded, when the risk assessment requires it, or when a competent authority requests it. Service may be suspended until the request is satisfied.
6. Restrictions
The Service is not provided to persons and entities included in applicable sanctions lists, to residents of jurisdictions under comprehensive sanctions, or to clients who refuse to provide required information.
Attempts to use the Service for unlawful activity result in refusal of service and, where required by law, notification of the competent authorities.
7. Suspicious activity
Suspicious operations are recorded and reviewed. The Service may decline an order, freeze an unused balance pending review, or terminate the relationship.
Where applicable law requires it, suspicious activity is reported to the competent authority; the client is not notified when such notification is prohibited.
8. Record keeping
Records of orders, payments, identification data and review decisions are retained for at least five years after the operation or the end of the relationship.
9. Responsibility and review
A designated officer of the Service is responsible for this policy. The policy is reviewed at least annually and whenever applicable regulation changes.
Questions and compliance requests: the Telegram bot @enralobot.