Account Review

Account review covers basic website compliance + business model / payment compliance + AIGC-specific compliance + legal page compliance. To protect consumers, keep the payment network secure, and comply with card network, payment partner, and applicable legal requirements, every merchant that wants to accept Card / USD payments through Anyway’s Merchant of Record service must complete an account review. Crypto (USDC) payments are not gated by this review: they remain available before, during, and after it. As a Merchant of Record, Anyway reviews your business model, website content, products, consumer policies, and potential risks. Passing the review does not grant permanent transaction eligibility. Anyway may continuously review or re-review your account based on subsequent product changes, transaction behavior, dispute rates, refund rates, consumer complaints, or regulatory requirements.

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1. Review scope — merchant identity

Merchants must provide truthful, accurate, and complete personal or business information. Depending on the account type, Anyway may request:

• Personal identity information and proof of identity;
• Business name, registration information, and registered address;
• Ultimate beneficial owner (UBO) information;
• The actual operating entity of the website or product;
• Settlement account information;
• Other materials required for KYC / KYB.

Submitting false, forged, impersonated, or misleading information may result in a rejected application or account suspension.

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2. Website basic requirements

Before applying for review, your website or product should be substantially complete and publicly accessible. A landing page only, a “coming soon” page, or a site where the core features cannot be tried usually cannot pass review. At a minimum, your website should clearly present:

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Product information

Users should be able to clearly understand:

• What product or service you offer;
• The product’s main features;
• How the product is used;
• What users receive after purchase;
• Whether the product is a subscription, credits-based, one-time purchase, or another pricing model.

Do not use false, exaggerated, or misleading product descriptions.

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Pricing information

If the website offers paid services, it should clearly display:

• The price of goods or services;
• The billing cycle;
• Whether auto-renewal applies;
• The price and purpose of Credits / Tokens / Points;
• Whether charges begin automatically after a free trial ends;
• Any other fees that may be charged to consumers.

Do not add mandatory fees after payment that were not previously disclosed.

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Contact information

The website must provide a genuine, actively maintained customer support channel, for example:

• A support email address;
• A Contact Us page;
• A live chat / support system.

Consumers must reasonably be able to reach the merchant.

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Legal pages

At a minimum, the website should publicly provide:

• Terms of Service / Terms & Conditions
• Privacy Policy
• Refund Policy

If you offer AI-generated content (AIGC), you should also provide:

• An Acceptable Use Policy (AUP) or an equivalent AI Content Policy

These pages should be accessible from the website footer, checkout, or another reasonable location.

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3. Terms of Service

Merchants must provide Terms of Service consistent with their actual business model. At a minimum, the Terms of Service should cover:

• The merchant or operating entity;
• The products and services offered;
• User account rules;
• How charges work;
• Auto-renewal rules;
• How to cancel;
• Rules for Credits / Tokens / Points (if applicable);
• Refund policy;
• Prohibited user conduct;
• Intellectual property;
• AI services and third-party model disclosures (if applicable);
• Service suspension and account termination rules;
• A link to the Privacy Policy;
• Contact information.

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Auto-renewal

If the product uses a subscription model, you must clearly state:

• The subscription price;
• The monthly / annual billing cycle;
• That the subscription renews automatically;
• That the user authorizes recurring charges;
• How to cancel the subscription.

Users must be able to cancel through a reasonable, clear process. Deliberately complex or misleading cancellation flows are not allowed.

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Credits / Points

If the product sells Credits, Tokens, Points, or similar virtual allowances, you should state:

• What the credits can purchase;
• Whether they expire;
• Whether they are refundable;
• Whether they are transferable;
• What happens to remaining credits when an account is closed;
• Whether an auto-top-up mechanism exists.

If auto-top-up is enabled, you must obtain the user’s explicit authorization in advance.

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Refunds

The refund policy must clearly state:

• Which situations qualify for a refund;
• Which situations do not;
• The refund request window;
• How to request a refund;
• The expected processing time.

The refund policy must be accessible before the user pays.

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4. Privacy Policy

Merchants must publicly provide a Privacy Policy that matches their actual data-handling practices. At a minimum, it should cover:

• Who the data controller is;
• What personal information is collected;
• Why it is collected;
• How the data is used;
• Cookie / analytics usage;
• Whether data is shared with third-party service providers;
• Data retention periods;
• Cross-border data transfers (if applicable);
• Users’ rights to access, correct, and delete their data;
• Rules for handling minors’ data;
• A contact for privacy questions.

If you use third-party analytics, AI, cloud, or login services, disclose them as appropriate. Where payment card information is handled by Anyway and its payment partners, merchants should not claim to store full card details themselves unless that is actually the case.

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5. AIGC-specific review

If your product lets users generate AI content via prompts, uploaded images, video, audio, or other inputs, Anyway performs an additional AIGC compliance review. This includes, but is not limited to: AI image generation, AI video generation, AI avatars, AI face swap, AI voice / voice cloning, AI characters / companions, AI chat, AI image editing, AI video editing, AI content generation platforms, and AI wrappers built on third-party models.

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Independent branding

The product must have its own brand, name, and positioning. Allowed:

Powered by / Built with OpenAI, Gemini, Claude, Flux, Kling, etc.

Not allowed (unless you actually hold the brand owner’s authorization):

Official ChatGPT Generator, Official Gemini Video Generator, OpenAI Official Image Generator

Do not use third-party AI models’ logos, trademarks, or names in a way that leads consumers to believe the product is officially operated by the model provider.

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Underlying model disclosure

For AI image, video, and other generative AI products, reasonably disclose the main underlying models or model providers actually used. For example:

Our service uses third-party AI models including OpenAI, Google Gemini, Flux and Kling.

If users can choose between models, showing model names directly in the product UI is sufficient. Do not:

• Invent models that do not exist;
• Misstate model versions;
• Pass off third-party models as proprietary models;
• Imply an official partnership with a model provider that does not exist.

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6. AIGC content moderation

AIGC merchants must maintain a genuine, effective content safety review mechanism. Merely stating “illegal content is prohibited” in the Terms of Service is not sufficient. The platform should moderate content at two stages, at minimum:

• Before generation: review user prompts, uploaded content, or other generation instructions.
• After generation: review AI output before it is displayed or delivered to the user.

If the platform has a public gallery, community, feed, or content-sharing feature, published content should also be continuously moderated. Merchants may use third-party moderation APIs, AI content-safety models, in-house review systems, keyword plus semantic models, human review, or any combination of these. During account review or ongoing risk review, Anyway may ask merchants to explain or provide evidence of their content moderation mechanisms.

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7. AIGC prohibited content

AIGC products must take reasonable measures to prevent users from generating, uploading, distributing, or selling the following content.

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Child safety

Strictly prohibited, with zero tolerance:

• CSAM;
• Sexual or sexualized content involving minors;
• Sexual innuendo directed at minors;
• AI-generated or fictional sexual content depicting minors.

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Pornographic and NSFW content

AI services whose primary purpose is generating pornography, sexually explicit content, or adult entertainment are not allowed. Merchants must not let users bypass content moderation through features such as an “NSFW Mode,” “Uncensored Mode,” “Adult Mode,” or disabling safety filters.

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Deepfakes and impersonation

Do not generate or distribute deepfake content of real people that could mislead others, without the person’s consent. In particular:

• Non-consensual sexual deepfakes;
• Celebrity sexual deepfakes;
• Identity impersonation;
• Fraud;
• Fake endorsements.

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Violent and extremist content

Do not generate:

• Extremely gory content;
• Terrorist propaganda;
• Extremist propaganda;
• Content depicting serious violence against real people;
• Content encouraging real-world violence.

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Hateful content

Do not generate content that seriously demeans, discriminates against, dehumanizes, or promotes violence against protected groups.

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Intellectual property infringement

Merchants should take reasonable measures to prevent:

• Unauthorized reproduction of copyrighted content;
• Impersonation of third-party brands;
• Unauthorized trademark use;
• Mass generation of clearly infringing content.

If the product involves AI image, video, or character generation, provide a reasonable channel for intellectual property complaints.

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8. Acceptable Use Policy (AUP)

AIGC merchants must publicly provide an Acceptable Use Policy, or include a complete AI Content Policy in their Terms of Service. At a minimum, the AUP should specify:

• What content may not be generated;
• What conduct is prohibited;
• How the platform performs automated content moderation;
• Whether human review exists;
• How users can report violations;
• How the platform handles violating content;
• What penalties violating accounts may face;
• How users can appeal (if applicable).

The moderation the platform actually enforces must match its published policy. Publishing an AUP purely to pass review, while the product actually lets users bypass the restrictions, is prohibited.

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9. Reporting and complaints

AIGC products should provide a genuine, working reporting channel, for example:

• abuse@[domain] or report@[domain];
• A website report form;
• An in-product Report button;
• A support email address.

Platforms that publish user-generated content publicly should offer content-level reporting. Reports involving child safety, fraud, deepfakes, or intellectual property should be handled with priority.

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10. Protection of minors

If the product may be used by minors, merchants must take reasonable protective measures appropriate to the product and its target markets. High-risk AI products may be required to:

• Set a minimum age;
• Provide an age declaration;
• Implement an age gate;
• Verify age for sensitive features;
• Block minors from adult or otherwise restricted content.

For products involving pornography, adult entertainment, or other categories Anyway prohibits, age verification does not make the product eligible for Anyway’s payment services.

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11. Prohibited and restricted categories

All merchants must also comply with Anyway’s Prohibited & Restricted Business Categories policy. If a product falls into a category Anyway explicitly prohibits, it cannot pass account review even if the website materials are complete, KYC/KYB is done, and Terms of Service, Privacy Policy, and content moderation are all in place. For restricted categories, Anyway may require additional business descriptions, product demos, licenses, authorization documents, content moderation evidence, age verification, supplier agreements, transaction data, or other risk controls.

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12. Review outcomes

Account review may result in:

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13. Ongoing review

Passing account review is not the end of the process. Anyway continuously monitors account risk. The following may trigger a re-review:

• Major changes to the product or website;
• New business lines;
• New AIGC / NSFW / UGC features;
• Domain changes;
• Sudden large increases in transaction volume;
• Abnormal refund rates;
• Abnormal chargeback rates;
• Increased fraudulent transactions;
• Large volumes of consumer complaints;
• Intellectual property complaints;
• Notices from regulators or payment networks;
• Actual operations inconsistent with the information provided at application.

After approval, merchants must not operate businesses that Anyway has not approved by modifying the product, hiding pages, redirecting domains, or other means. Material business changes should be reported to Anyway promptly.

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Pre-submission checklist

Before submitting your account for review, confirm: Website

• The website is live
• The product’s features and business model are clear
• Pricing is public and transparent
• There is a genuine, working support email
• Users can actually purchase and use the product

Legal policies

• Terms of Service
• Privacy Policy
• Refund Policy
• Auto-renewal rules (if applicable)
• Credits / Points rules (if applicable)
• AUP / AI Content Policy (AIGC products)

AIGC

• Independent branding
• No impersonation of underlying model providers’ official products
• Main underlying AI models disclosed
• Prompt-level content moderation in place
• AI output content moderation in place
• NSFW / CSAM / deepfake and other high-risk content blocked
• User reporting mechanism in place
• Process for handling violating content and accounts in place

Payments

• Users see the price before paying
• Users clearly know whether auto-renewal applies
• Users can easily cancel subscriptions
• The refund policy is accessible before payment
• Checkout matches the price and product shown on the website

Completing these items improves review efficiency but does not guarantee approval. Anyway makes the final decision based on your specific business model, target markets, payment network requirements, and overall risk level.