You understand and agree that Dwolla is authorized, pursuant to general parameters of conduct established by Veridian, to take the following actions due User misconduct or Security Concerns as detailed in this section:
● Place a Hold on Your User Account for Up to 90 days:
● Temporarily or Permanently Suspend or otherwise Limit Your Access to Your User Account:
● Contact Users who have purchased goods or services from You, contact Your bank or credit card issuer, and/or warn other Users, law enforcement, or impacted third parties of Your actions; or
● Take legal action against you
If Dwolla, acting in accordance with the general parameters of conduct established by Veridian, takes an action against Your User Account, including: placing a hold on, suspending or otherwise limiting Your access to, or terminating Your User Account, We will provide You with notice that such action has been taken against Your User Account. Dwolla may also provide the opportunity to request restoration of access if it is deemed appropriate by Dwolla acting in accordance with the general parameters of conduct established by Veridian.
User Misconduct or Security Concerns that may result in any of the above listed actions, as applicable, include:
● Your Non-compliance with the User Conduct Requirements detailed in this Agreement, including attempting to use the Dwolla system for illegal purposes or attempting to falsify your identity or provide false information;
● Inability of Dwolla to acquire sufficient information to verify your identity;
● A determination by Dwolla, pursuant to general parameters of conduct established by Veridian, that a Hold on Your User Account is reasonably needed to protect against the risk of liability;
● A determination by Dwolla, pursuant to general parameters of conduct established by Veridian, that there may be a high level of risk associated with You, other Dwolla users involved in the payments You receive, Your User Account, or any or all of Your transactions.
You understand and agree that you will not engage in the following activities:
● Use the Dwolla System without written consent to operate or engage in any business regulated by FinCen, including the money service business;
● Act as a marketplace and/or exchange for virtual currency products without prior written consent;
● Use the Dwolla System in association with or for payment of illegal goods or service, including, but not limited to, illegal substances, illegal online gambling/ wagering, pyramid schemes, or any type of money laundering;
● Attempt to falsify Your identity, such as by providing false account information or false documents; or
● Defraud Dwolla, Veridian, or other Dwolla Users in any way.
You understand and agree:
● You will provide information requested to determine your identity, including but not limited to the following: a valid U.S. address, phone number, Financial Institution account information, photo identification, and/or tax identification or social security number.
● You authorize Dwolla, directly or through Veridian or third parties, to make inquiries it considers necessary to validate Your identity, such as requesting additional information to validate Your Financial Institution account ownership, identity, and transaction authorization. This information is requested to protect Dwolla Users.
Their actions aren't really unexpected. It's been fairly typical that when the exchanges find new payment processors/"banking partners" those businesses start enforcing AML/KYC requirements fairly strictly once any significant amount of Bitcoin-related business starts passing through their customer accounts.