1. Purpose & scope
This policy sets out how Velora prevents money laundering, terrorist financing, sanctions breaches, fraud and the publication of prohibited content, in line with our acquiring bank, the card schemes (Visa high-risk / Integrity Risk Program; Mastercard BRAM) and applicable AML law. It applies to all users, staff and moderators, and to every payment, messaging and content surface of the platform. Users buy credits and spend them on messages, letters, gifts and video.
2. Client verification — KYC, due diligence & ongoing monitoring
After registration and submission of a selfie, the user is verified before they can interact. Until verification is complete the user remains invisible and cannot contact anyone. If any trigger arises, a compliance employee contacts the user for additional information and may block the account. We use the following systems:
| Purpose | Vendor | Function |
|---|---|---|
| Identity + age (18+) verification, document + selfie liveness | Sumsub | Confirms the user is a real, 18+ individual at onboarding |
| Selfie / photo & content risk scoring | HIVE | Automated check of the registration selfie and all uploaded media |
| Sanctions, PEP & adverse-media screening + ongoing monitoring | ComplyAdvantage | Screens every registrant and payer against global sanctions, PEP and adverse-media lists, with continuous re-screening |
| Crypto exposure (where applicable) | Elliptic | Wallet screening / source-of-funds |
| Chargeback (CHB) management | Ethoca and Verifi | Pre-dispute alerts, deflection, evidence collection |
| Content scanning (text & image) | OpenAI and G2 LLC | Detect illegal, immoral and socially-unacceptable content (pornography, child sexual abuse material, politically provocative content, escort and similar) |
| CSAM detection & reporting | PhotoDNA + NCMEC | Hash-matching and mandatory reporting of child sexual abuse material |
Age verification (18+ only): a hard 18+ gate at registration plus documentary ID and selfie liveness — under-18 accounts are refused and blocked. Bans are enforced by linking the user's email and profile name; for payments, blocking is applied by BIN (Bank Identification Number) so a blocked user cannot re-register or re-pay. Ongoing monitoring includes continuous sanctions / PEP re-screening, transaction monitoring (velocity, high-value top-ups, mismatched geo / BIN) and Enhanced Due Diligence for high-risk indicators.
3. Fraud, chargeback & scam monitoring
- One account per person — duplicate-registration control via email, device, BIN and behavioural signals; second accounts are blocked.
- Fake-profile and AI-generated-avatar detection — uploaded photos are screened for synthetic / AI imagery and stock or celebrity reuse; suspected fakes are held for review.
- Anti-catfishing / romance-scam controls — pattern detection for off-platform money requests and scripted scam language.
- Chargebacks — users contact our Client Care Centre, where documents and information are collected; disputes are handled with Ethoca, Verifi and ComplyAdvantage. Chargeback ratios are managed within scheme limits.
- A Report control on every profile and every message; reports are triaged and can trigger takedown, account block, refund handling or law-enforcement referral.
4. Content moderation program
Content control is a layered program covering profiles, photos, video and chat:
- Automated AI screening (first line) — all profiles, photos, videos and messages are scanned by HIVE and OpenAI / G2 for nudity / adult, CSAM, violence / terror, escort / solicitation, hate and copyright-infringing content. Text is additionally filtered for terrorism-related and scam / fraud language.
- Human moderation (second line) — approximately 38 staff perform manual monitoring and content moderation, reviewing AI alerts and processing alerts related to inappropriate or nude content.
- User reporting (third line) — in-product reporting escalates content and behaviour to the team.
Visual & text screening: no adult content is permitted; every photo and video is screened for nudity, adult and copyright-infringing content before it is shown.
Moderation flow (step-by-step):
- Content submitted → automated scan (HIVE / OpenAI).
- Clean → published; flagged → quarantined (not publicly visible) pending review.
- A human moderator reviews the alert within our service level.
- Action: approve, edit-request, remove, warn, suspend, or permanently ban (email + profile-name link; BIN block for payment abuse).
- Escalation: CSAM → PhotoDNA + NCMEC report; sanctions / AML → MLRO; fraud → risk team + chargeback vendors.
- Every decision is logged with reviewer, timestamp, reason and evidence.
CSAM — zero tolerance: suspected material is hash-matched, the account frozen, content preserved, and reported to NCMEC and local authorities, with no warning to the user.
5. Prohibited content & activities
The following are strictly prohibited and cause content removal and/or a permanent ban:
- Any content involving minors; child sexual abuse material (reported to authorities / NCMEC).
- Escort, prostitution, or any sexual service for money, and solicitation of the same.
- Adult, pornographic, or nudity content of any kind.
- Fraud, scams, romance fraud, phishing, or requests to move money off-platform (bank transfer, gift cards, cryptocurrency, wire).
- Human trafficking, exploitation, coercion.
- Dealings with sanctioned parties or from sanctioned countries.
- Weapons, drugs, or illegal-goods solicitation.
- Hate, harassment, violence, terrorism or extremism, and self-harm promotion.
- Impersonation, fake or AI-generated identities, catfishing, and duplicate accounts.
- Copyright or intellectual-property-infringing media.
- Money laundering or terrorist financing in any form.
6. Payments & high-risk compliance
- Merchant category: dating (MCC 7273), treated as high-risk; we expect registration under Visa's high-risk / Integrity Risk Program with enhanced monitoring, and comply with Mastercard BRAM.
- Transparent credit pricing (no subscriptions or hidden renewals), a clear billing descriptor, visible refund and cancellation terms, and accessible customer support.
- The platform sells only dating credits — no adult or escort payment categories.
7. Sanctions & jurisdiction
Velora operates no business, users, staff, payments or infrastructure connection with sanctioned countries. Registrations, cards / BINs and traffic associated with sanctioned jurisdictions are blocked, and no sanctioned-country locations are marketed or featured on the platform.
8. Governance & data protection
- An MLRO / Compliance Officer owns AML / KYC, sanctions and suspicious-activity reporting; a Trust & Safety lead owns the content program.
- Staff and moderators receive AML, sanctions, CSAM-handling and content-policy training at onboarding and at least annually.
- Personal and verification data is processed lawfully, stored securely, and retained only as long as required. Users are anonymous to one another until they choose to exchange contact details. Payments are handled by PCI-DSS-compliant processors; we do not store full card numbers.