Compliance, KYC & AML policy
Bag App by BagWire LLC · Virginia, United States · Version 1.0, September 2026
1. Scope and operating model
Bag App is operated by BagWire LLC (Virginia). Bag App does not take custody of member funds and does not move money on its own authority. All regulated money movement is performed by a licensed payment partner or sponsor bank, which holds member balances in a pooled custodial account. Bag App is responsible for member identification, the balance ledger, transaction monitoring and member support.
2. Customer identification (KYC)
Every member provides first name, last name, email address and mobile number at sign-up and accepts the Terms and Privacy Policy. Before a member can move money beyond the introductory limit, Bag App collects legal name, date of birth, full residential address, the last four digits of the Social Security number and a government-issued photo ID (front and back). Documents are stored in private encrypted storage accessible only to the member and to compliance review. Members must be 18 or older. Duplicate identities and mismatched details are rejected and reviewed manually.
3. Customer due diligence and risk rating
Each member is rated low, medium or high risk based on age of account, verification status, funding method, transfer volume and monitoring history. High-risk members are subject to enhanced due diligence: source-of-funds questions, reduced limits and manual approval of transfers. Bag App does not knowingly onboard members appearing on sanctions or watch lists; screening is performed by the payment partner and, once contracted, an identity-verification provider.
4. Transaction monitoring rules
Every transfer is screened automatically as it is recorded. Current blocking rules: (a) velocity — 20 or more sends by the same sender within one hour; (b) repeated amounts — 20 or more identical amounts from the same sender within 24 hours; and (c) new-account risk — an account under 24 hours old moving $2,500 or more. Matches create a dated flag with severity for compliance review. Flags are private to compliance and are retained with the transaction record.
5. Limits
Minimum transfer $10. Maximum transfer $5,000. Maximum $5,000 per rolling 24 hours and $10,000 per rolling 7 days per sender. Limits are enforced in the database at the moment of transfer, not only in the app, so they cannot be bypassed by a modified client. Card top-ups are capped at $2,500 per load.
6. Suspicious activity and reporting
Flagged activity is reviewed by the compliance contact named below. Where a transaction appears to involve fraud, structuring, or funds from unlawful activity, Bag App freezes the affected balance, notifies the licensed payment partner and supports the partner's Suspicious Activity Report filing. Once Bag App is itself a registered money services business, SARs and CTRs will be filed directly within the statutory deadlines.
7. Recordkeeping
Member identity records, transfers, deposits, withdrawals, fee amounts, support cases and monitoring flags are retained for at least five years after account closure, as required for money-services recordkeeping. Members can request a copy of their own records, and deleting an account removes it from the live app while retained compliance records are held separately for the statutory period.
8. Disputes, refunds and reversals
Members can open a case in the app under Support & Disputes: wrong payment, refund request, failed payment or other. Cases are acknowledged within one business day and payment disputes are investigated within 10 business days. Completed member-to-member transfers are final; where money reached the wrong person, Bag App contacts the recipient and requests a reversal through the payment partner where card-network rules allow. Failed card transactions are returned to the originating balance and the member is notified with the reason.
9. Training and review
Everyone with access to member data completes AML and data-handling training before access is granted and annually thereafter. This policy is reviewed at least annually, and immediately whenever the payment partner, product limits or licensing position changes. An independent review of the AML programme will be commissioned before public launch.
10. Licensing position
Bag App does not process public transfers until a licensed payment partner has approved the programme and a money-transmission attorney has reviewed the Terms, Privacy Policy, KYC flow and limits. Virginia is the launch state; Bag App operates under a licensed partner's authority or a Virginia money transmitter licence, not without either.
Named compliance contact
The AML/BSA compliance officer for Bag App by BagWire LLC is the company founder and is reachable directly at the address below. Partners, banks and regulators can use this address for programme questions, information requests and escalations.
compliance@bagwire.appPartnerships: partners@bagwire.app