Version 1.0 · Effective 14 September 2026 · Next full review by 14 September 2027
This Policy describes the risk-based measures used by Recorise Ltd, operating the Netts service (“Netts”, “we”, “us”), to prevent the Services from being used for money laundering, terrorist financing, sanctions evasion, fraud, phishing, ransomware, theft or other unlawful activity.
It applies to Netts websites, APIs, bots, dashboards, TRON Energy and Bandwidth delegation, address activation, blockchain analytics, prepayments, internal service balances, withdrawals, post-paid billing and related services.
Netts provides blockchain infrastructure, software, APIs and temporary delegation of protocol-level computational resources, including TRON Energy and Bandwidth.
Netts does not request or control a customer’s external-wallet private keys or seed phrases and does not initiate or sign token transfers from a customer’s external wallet. Resource delegation does not give Netts authority to transfer assets held in the receiving wallet.
Recorise Ltd does not represent Netts as a licensed virtual-asset exchange, wallet or custodial service. The Services are network-resource and software/API services. The regulatory characterisation of a particular arrangement may depend on the agreed service model and applicable law.
Netts may accept fiat or supported digital-asset payments. Depending on the service model, a payment may be a prepayment recorded as an off-chain service balance or a post-paid settlement of Services already delivered and invoiced.
Netts may provide standard self-service access without prior identity verification. Such access remains subject to technical controls, sanctions screening, wallet and transaction monitoring, limits and the right to request additional information.
Corporate, high-volume, post-paid, credit-based, dedicated-SLA or intermediary arrangements may require business verification before activation.
Settlement may be made in fiat currency or supported digital assets. Digital-asset payments may be received to Recorise-controlled blockchain addresses or to corporate accounts maintained in the name of Recorise Ltd with approved third-party digital-asset service providers.
In a post-paid arrangement, the payment settles an invoice for Services already delivered and no prepaid customer balance is maintained for that arrangement.
Netts applies controls proportionately to risk. Relevant factors may include:
A low-risk rating or a successful automated check does not guarantee that a customer, address or transaction is free from unlawful activity.
Netts does not require the same level of identification from every customer.
Netts may request personal identification, company information, ownership information, proof of authority, proof of wallet control, source-of-funds information, regulatory information or an explanation of a transaction or use case where justified by risk.
Business verification may include legal name and registration details, directors, authorised representatives, beneficial owners, ownership and control structure, business activity, regulatory status, relevant countries, expected volumes and approved payment methods.
Netts may refuse, limit or suspend Services where requested information is not provided, cannot be verified or does not adequately address the identified risk.
Netts applies sanctions, internal-list and blockchain-risk screening to digital-asset deposits and withdrawals under its risk-based controls.
Netts may review the transaction identifier, originating or destination address, asset, network, amount, customer relationship and relevant blockchain exposure. The depth and timing of screening may vary by transaction type, asset, product and risk profile. A payment or withdrawal may be placed on compliance hold while an alert is reviewed.
A technical failure or unavailable screening provider is recorded and handled under the applicable control rules; it is not silently treated as a successful screening result.
Every resource-delegation request is checked against the central Netts address deny list before fulfilment.
A request involving an address included in the deny list is rejected. The affected request is not forwarded to an internal or external resource provider for fulfilment.
The deny list may include addresses associated with sanctions, token-issuer restrictions, phishing, scams, ransomware, malware, stolen assets, fraud, law-enforcement information, internal abuse findings or other unacceptable risk.
Netts uses third-party blockchain analytics, including Elliptic, together with internal intelligence and risk classifications.
Enhanced screening may be applied based on the customer profile, first use of an address, transaction value or volume, unusual behaviour, risk alerts, contractual enterprise requirements, targeted review, random sampling or periodic rescreening.
Not every receiver address receives the same depth of blockchain analysis. External datasets and automated tools may be incomplete and cannot identify every unlawful or high-risk address.
The Services must not be used by, for, on behalf of or for the benefit of a person or entity subject to applicable sanctions or asset-freeze restrictions, or to facilitate sanctions evasion.
Netts may also refuse resource delegation to an address included in a token-issuer blacklist, including an applicable USDT issuer blacklist. A token-issuer blacklist is treated as a separate operational and risk control and is not necessarily a government sanctions list.
The Services must not be used in connection with:
Attempted, indirect or facilitated use may be treated in the same manner as direct use.
Netts may provide Services through an independent reseller, channel partner, contractor or other contractual intermediary acting in its own name and for its own account.
Netts applies risk-based due diligence to such an intermediary and may request information concerning a disclosed business end customer, its ownership, regulatory status, intended use, payment arrangements or designated wallet addresses.
The use of an intermediary does not permit any customer, payment or address to avoid Netts sanctions, prohibited-use or risk controls.
Depending on the circumstances, Netts may:
Netts will not automatically return value to a prohibited or sanctioned address. Any release, return or other disposition is subject to compliance review and applicable law.
To assess the risk associated with a blockchain address, Netts submits that public address, and where relevant a public transaction identifier, to approved blockchain analytics providers, including Elliptic, and receives a risk assessment in return. Netts does not send a customer’s name, contact details, account data or identity documents to such a provider, and the assessment received is processed within Netts systems.
Where an order is fulfilled through an external resource provider, Netts may disclose the public receiver address and the minimum order data necessary to perform the delegation. A rejected deny-list request is not forwarded for fulfilment.
Relevant information may also be disclosed to infrastructure and security providers, professional advisers, auditors, banks, approved digital-asset service providers, insurers or competent authorities where necessary and subject to applicable confidentiality, security and legal requirements.
Netts does not sell customer or receiver-address lists.
Resource delegation and related blockchain transactions may create permanent public records, including transaction identifiers, block data, source addresses, receiver addresses and resource quantities. Netts does not control the public blockchain and cannot alter or erase records maintained by the network.
Blockchain records identify addresses and transactions but do not necessarily identify the natural or legal persons controlling those addresses.
Netts separately retains customer, payment, contractual, screening, risk and operational records under its data-retention standards. Off-chain records may be deleted, anonymised or de-linked when the applicable retention period expires, unless continued retention is required for legal, contractual, security, investigation or claim purposes.
Netts assigns responsibility for this Policy and maintains internal controls, testing, audit evidence and staff instructions appropriate to its business and risk profile.
This Policy is reviewed at least annually and after a material change to the Services, customer profile, payment methods, screening technology, sanctions environment or applicable requirements.