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Terms & Policies

SugarGlitch — AML / Anti-Fraud Policy

Last Modified: April 20, 2026

This AML / Anti-Fraud Policy is published by SugarGlitch Ltd, a Cyprus private limited company ("SugarGlitch," "we," "our," or "us"), and is incorporated into our Terms of Service.

Money laundering, sanctions evasion, and payment fraud are illegal and cause real harm. Although SugarGlitch is a content platform — not a regulated financial institution — we take measures to prevent, detect, and address these activities on our Services. This Policy describes our approach.

This Policy works alongside our Terms of Service, Refund Policy, Privacy Policy, and other policies. Our payment processors are independently subject to anti-money-laundering obligations under the laws of their respective jurisdictions, and they apply their own controls in addition to ours.

1. What Money Laundering and Fraud Mean

Money laundering is the process of disguising the origins of money obtained through criminal activity so it appears to come from lawful sources. Payment fraud is obtaining money or services through deception — for example, by using stolen payment cards, taking over another person's account, or initiating chargebacks for goods and services that were in fact received.

Both are prohibited on the Services.

2. Our Approach

We work with established payment processors that perform their own anti-money-laundering and fraud controls, and we layer additional measures on top. Specifically, we may:

  • Use the fraud-prevention and screening tools provided by our payment processors
  • Apply transaction-level checks on payments, including for inconsistent or anomalous activity
  • Apply account-level checks to identify patterns associated with abuse, fraud, or coordinated activity
  • Block payments and account activity from jurisdictions subject to comprehensive sanctions under U.S., EU, UK, or other applicable sanctions regimes
  • Restrict, hold, or refund transactions where we believe doing so is necessary to prevent fraud, money laundering, or violation of applicable law
  • Cooperate with law enforcement and regulators in response to lawful requests

3. Red Flags

We monitor for indicators that may suggest fraud, money laundering, or related abuse. Indicators include, without limitation:

  • Multiple payment attempts using different cards or names from the same account or device
  • Rapid, repeated, or unusually large purchases in a short period
  • Payment attempts from IP addresses or networks associated with elevated fraud risk
  • Use of disposable email domains, anonymizing services, or other tools designed to obscure identity in patterns that suggest abuse
  • Account behavior inconsistent with normal use of the Services
  • Mismatch between billing information and other account signals
  • Transactions originating from, or routed through, sanctioned jurisdictions
  • Patterns suggestive of card testing, account takeover, or coordinated chargeback abuse

The presence of one or more of these indicators does not necessarily mean a violation has occurred — context matters, and we apply judgment.

4. Cryptocurrency

We may accept payment in cryptocurrency. Cryptocurrency transactions create elevated fraud and laundering risk because of their irreversibility and the possibility of obscured origins. For cryptocurrency transactions we may:

  • Use third-party blockchain analytics tools to screen transactions and wallet addresses against known illicit-activity indicators and sanctions lists
  • Decline transactions associated with high-risk wallets, mixers, or sanctioned counterparties
  • Apply transaction limits or holds where appropriate

All cryptocurrency transactions are also subject to the Refund Policy.

5. Sanctions

We do not knowingly transact with individuals, entities, or jurisdictions subject to comprehensive sanctions under U.S. (OFAC), EU, UK, or other applicable sanctions regimes. We may screen accounts, transactions, and counterparties against applicable sanctions lists, and we will block, freeze, or refund transactions as required by law if we identify a sanctions match. Users are responsible for ensuring that their use of the Services complies with all sanctions laws applicable to them.

6. When We Suspect Fraud or Money Laundering

When we detect or receive reports of suspicious activity, we investigate. Depending on what we find, we may:

  • Hold, decline, refund, or reverse the transaction
  • Suspend or terminate the associated account, with or without prior notice
  • Forfeit unused Credits or subscription benefits associated with fraudulent transactions
  • Refer the matter to our payment processors and to law-enforcement or regulatory authorities where appropriate
  • Cooperate fully with government, law-enforcement, and regulator requests regarding suspicious accounts or transactions

We may take any of these steps before contacting the affected user, particularly where doing so is necessary to prevent ongoing harm or where notifying the user could compromise an investigation.

7. Chargebacks

Initiating a chargeback for a legitimate transaction without first contacting us is a form of payment abuse. Our approach to chargebacks is described in the Refund Policy. Repeated chargeback activity may be treated as fraud under this Policy.

8. Reporting Suspicious Activity

If you encounter activity on the Services that you believe involves fraud, money laundering, or related abuse — including suspected account takeover or unauthorized use of your payment information — please contact us immediately at [email protected] with the subject line "Fraud Report." Include any information that helps us identify the activity, such as account names, transaction details, and a description of the issue.

We treat these reports as a priority. If your account or payment information has been compromised, please also contact your card issuer or payment provider directly.

9. Changes to This Policy

We may update this Policy from time to time as we refine our controls, as our payment infrastructure changes, or as the law evolves. The date of the most recent update is shown at the top of this Policy.

10. Contact Us

For questions about this Policy or to report suspicious activity:

SugarGlitch Ltd
[REGISTERED ADDRESS — TBD]
Cyprus
Email: [email protected]