Draft — pending legal review · text as of 5 August 2026
Anti-Money-Laundering Policy
[LEGAL_ENTITY] ("Mason Lab", "we") operates a marketplace that holds customer funds in escrow. Because we hold funds, we apply anti-money-laundering and sanctions controls to every account and every transaction. This policy explains what we do, what we require from you, and what we will refuse. It forms part of the Terms of Service and is pending review by counsel before it takes effect.
Effective date: [EFFECTIVE_DATE] · Governing law: [JURISDICTION] · Contact: [CONTACT_EMAIL_OR_TELEGRAM]
Placeholders to be completed before publication
- [LEGAL_ENTITY] — registered name of the company operating Mason Lab
- [JURISDICTION] — country of incorporation and governing law
- [CONTACT_EMAIL_OR_TELEGRAM] — compliance contact channel
- [EFFECTIVE_DATE] — date this policy takes effect
- [SCREENING_PROVIDER] — blockchain analytics provider used to score addresses
- [SCREENING_THRESHOLD] — amount from which screening is mandatory (zero = every deposit is screened)
- [RESTRICTED_JURISDICTIONS] — countries and territories from which the Platform may not be used
- [RETENTION_YEARS] — retention period for payment, screening and compliance records
- [SLA_HOURS] — response time on a restricted account
Not yet in effect
No payment provider is connected. Mason Lab does not currently accept payments and holds no customer funds, so none of the controls below has yet had anything to act on. They are the rules that apply from the first payment we accept, and each is a precondition for opening payments — not a promise made after the fact:
- recording of the payer address on every incoming payment;
- risk screening of incoming payments and of payout destinations;
- deposit, turnover and withdrawal limits;
- returns to the originating address;
- the ability to stop deposits and payouts platform-wide with one action.
1. What we do
- We record where money comes from. For every incoming payment we store the originating address, the transaction hash, the network, the confirmations and the amount actually received. Without that record neither a return nor any meaningful screening is possible, so a payment we cannot attribute to an address is not credited.
- We screen incoming payments. A deposit is screened for risk before it is credited to your balance, using a third-party blockchain analytics provider ([SCREENING_PROVIDER]). Screening applies to every deposit at or above [SCREENING_THRESHOLD], and we may screen any payment of any size. Screening looks at the source of the funds, not at your identity.
- We screen withdrawal destinations. Payout addresses are screened before funds are sent.
- We monitor activity for patterns associated with money laundering, including structuring, rapid pass-through of funds, trades between related accounts, fictitious or self-dealing trades, repeated trading between the same two accounts, round amounts, and orders where the delivered item was never opened.
- We apply limits. Deposit, turnover and withdrawal limits apply to every account. Limits depend on account age and history and may be raised on request or reduced at our discretion.
- We hold new-seller payouts for a review period before the first withdrawal is released.
- We keep records of payments, screening results and compliance decisions for at least [RETENTION_YEARS] years, and we retain them after an account is closed. A request to delete personal data does not override that obligation — see the Privacy Policy.
2. What we require from you
- Your own funds, your own account. You may only deposit funds that belong to you and come from a lawful source. You may not deposit or withdraw on behalf of another person.
- One account per person. Operating multiple accounts to circumvent limits, reviews or restrictions is prohibited.
- Truthful information. Information you give us — including your Telegram identity and anything provided during a review — must be accurate.
- Cooperation with review. We may ask you to explain the source of funds or the nature of a transaction. We ask for the minimum necessary and we do not require identity documents for ordinary use of the Platform.
3. Verification
We may request verification from any user at any time, in particular before a large withdrawal, on unusual activity, or where required by law. Until a requested verification is completed, we may limit deposits, purchases or withdrawals on the account. Your balance remains yours during a review; it is not forfeited and it does not expire.
4. Prohibited use
You may not use Mason Lab to:
- launder proceeds of crime, finance terrorism, or evade sanctions;
- move funds between third parties, using the Platform as a transfer or pass-through service;
- transact with accounts you control or coordinate with in order to create the appearance of trade, including trades placed to build reputation, rating or volume;
- structure payments to stay below any limit or review threshold;
- pay for anything that is not the digital item described in the listing, or use a listing as a cover for another transaction;
- transact from a restricted jurisdiction or on behalf of a sanctioned person or entity.
Breach results in termination of every linked account, withholding of balances pending investigation, and reporting where required by law.
5. Restricted jurisdictions and sanctions
The Platform may not be used from, or on behalf of persons located in or ordinarily resident in, [RESTRICTED_JURISDICTIONS], or by any person subject to applicable sanctions. We screen blockchain addresses against sanctions data provided by our screening provider. Using a VPN, a proxy or another person's details to circumvent a restriction is itself a breach of this policy.
6. Refunds and withdrawals go back to the source
Refunds and withdrawals of unused balance are returned only to the address the funds came from. You cannot nominate a different destination. If you deposited from several addresses, funds are returned to those addresses in the order the deposits were received. Network fees are deducted from the amount returned.
This rule exists to prevent the Platform from being used to move funds between wallets, and it applies without exception. See §9 of the Terms and §4 of the Refund Policy.
7. Our right to refuse, hold and freeze
We may, at our discretion and without prior notice:
- decline a deposit and return it to the address it was sent from, less network fees, where screening indicates high risk;
- decline, delay or cancel a withdrawal;
- place a hold on an account, a balance or a specific transaction while we complete a review;
- limit or close an account and end our relationship with a user;
- suspend deposits, purchases and payouts platform-wide where the integrity of the funds we hold is at risk, including at the direction of a payment provider — in which case balances are frozen as they stand and we say so plainly through the Telegram bot, with a named incident and a next-update time;
- report suspicious activity to competent authorities where required by law and, where the law requires it, without informing the user.
We will tell you when your account is restricted and what the status of your funds is. We will not disclose the specific detection rules or thresholds that triggered a review, and we may be legally prohibited from disclosing that a report has been made.
Where funds cannot be returned to their source for technical reasons — for example, the sending address cannot receive funds, or our payment provider will not process the return — the funds are held pending resolution, and we will tell you so.
8. Reporting and questions
If you believe an account or a listing is being used for money laundering or another financial crime, contact [CONTACT_EMAIL_OR_TELEGRAM]. If your account has been restricted and you believe this is an error, reply through the same channel; we respond within [SLA_HOURS] hours.
9. Changes
We may update this policy. Material changes are announced before they take effect. Continued use of the Platform after the effective date of a change constitutes acceptance.