This policy is adopted by HONGKONG LINGYUN NETWORK MDT INFOTECH LIMITED, Flat/Rm 401, 4/F, Wanchai Central Building, 89 Lockhart Road, Wan Chai, Hong Kong, which operates PyProxy. We accept cryptocurrency, and that places obligations on us to prevent our service being used to launder funds or to move value for sanctioned parties. This policy sets out how we meet them.
Principles
We sell a low-value digital service to a large number of small customers. That is a poor vehicle for laundering, and we keep it that way by refusing the patterns that would make it a good one: we do not hold customer balances as withdrawable funds, we do not transfer value between customers, and we do not pay anyone out except as a refund to the payer.
No stored value
Money you pay becomes proxy traffic. It cannot be withdrawn, sent to another user, or converted back to cryptocurrency except through the Refund Policy, which pays only to the original payer. There is no wallet, no peer-to-peer transfer, and no cash-out path.
Customer due diligence
Ordinary purchases require only a working email address. We ask for identity verification where risk indicators appear, including:
- Cumulative purchases above the equivalent of USD 1,000 in any 30-day period.
- A single purchase above the equivalent of USD 1,000.
- Payments from wallets flagged by our processor's screening as linked to a mixer, a sanctioned address, darknet markets, or known fraud.
- Structuring: repeated purchases sized to sit just under a threshold.
- Requests to refund to a wallet other than the one that paid.
Verification means a government-issued identity document and, for companies, proof of registration and of who controls the company. Refusing verification means we refund the payment and close the account rather than continue the relationship.
Sanctions
We do not knowingly deal with individuals or entities on EU, UK, UN or OFAC sanctions lists, nor with parties acting on their behalf. Payments from screened-sanctioned wallet addresses are rejected and not fulfilled.
Transaction monitoring
Incoming payments are screened by our payment processor before we treat an order as paid. We review orders that our own checks flag as unusual in size, frequency or pattern, and we hold fulfilment until a flagged order is reviewed.
Record keeping and reporting
We retain order and payment records, and any verification documents we collect, for the period required by applicable law. Where we form a suspicion of money laundering or terrorist financing, we report it to the competent authority and we do not tell the customer that we have done so, because the law forbids it.
Responsibility
Compliance questions, including requests from law enforcement, should go to service@pyproxy.com and will be routed to the person responsible for this policy.
If anything here is unclear, email service@pyproxy.com before you buy. We would rather answer a question than process a dispute.