Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy

EXPAT LEGAL OÜ (the "Platform") is committed to preventing money laundering and terrorist financing through its platform. This policy applies to all transactions processed through EXPAT LEGAL.

EXPAT LEGAL operates as a technology platform facilitating escrow services. Payment processing is handled by Mercuryo, a licensed Electronic Money Institution (EMI) authorised by the relevant European regulatory authorities. Mercuryo's own AML/KYC procedures apply to all payment transactions.

EXPAT LEGAL has assessed its money-laundering risk as LOW–MEDIUM, based on:

• Average transaction value: $30–$300 (low value).
• Service type: professional consultations (not anonymous cash transfers).
• Client base: identifiable diaspora individuals with a verifiable need.
• Payment processor: a licensed EMI (Mercuryo) with its own AML controls.

3.1 Standard CDD applies to all clients:

• collection of contact information (email or phone);
• IP-based location verification;
• payment processed through a licensed EMI (Mercuryo handles KYC).

3.2 Enhanced Due Diligence (EDD) applies when:

• a transaction value exceeds $500 in a single payment;
• multiple transactions from the same contact within 24 hours total more than $500;
• payment originates from a high-risk jurisdiction (as defined by the FATF);
• transaction patterns are inconsistent with the stated purpose.

3.3 When EDD is triggered, EXPAT LEGAL may:

• request proof of identity before releasing escrow;
• delay the transaction by up to 48 hours pending review;
• decline the transaction and refund if verification fails.

The 5-step specialist verification process (diploma, licence, ID, interview, ongoing monitoring) serves a dual purpose: quality assurance AND anti-fraud / AML control. Verifying the identity of service providers reduces platform-abuse risk.

EXPAT LEGAL monitors for:

• multiple payments for the same specialist within a short timeframe;
• requests to split large payments into smaller ones;
• unusual geographic combinations (e.g. payment from a sanctioned jurisdiction);
• requests to cancel immediately after payment (potential fraud testing);
• a client requesting a refund then immediately repaying (a layering indicator).

Transaction records are retained for a minimum of 5 years, per Estonian AML regulations, including:

• payment amounts and dates;
• contact information provided;
• the specialist involved;
• the transaction outcome (completed / refunded / disputed).

EXPAT LEGAL will report to the Estonian Financial Intelligence Unit (FIU) if:

• transactions are suspected to involve the proceeds of crime;
• terrorist financing is suspected;
• requests are received from law enforcement.

EXPAT LEGAL does not process transactions involving:

• individuals on EU, US OFAC or UN sanctions lists;
• entities from sanctioned jurisdictions (as updated by the EU / OFAC);
• transactions that would violate applicable sanctions regulations.

Our payment-processing partner Mercuryo maintains its own sanctions screening.

The designated Money Laundering Reporting Officer (MLRO) for EXPAT LEGAL OÜ is the platform's compliance officer. Contact: compliance@expatlegal.com.

All suspicious-activity reports are reviewed by the MLRO within 24 hours.

This policy is reviewed annually and updated whenever regulatory requirements change.