Start typing to search…

Anti-Fraud Policy

Last updated: 12 January 2026
Legal Entity: Aigen LLC
Brand / Trade Name: ItIsPay
Website: https://itispay.com

1. Purpose and Scope

Aigen LLC (“Aigen”, “Company”), operating under the brand name ItIsPay, is committed to preventing, detecting, and mitigating fraudulent activity in connection with the provision of its technology, APIs, software services, and related operational support.

This Anti-Fraud Policy outlines the principles, controls, and procedures adopted by Aigen to:

  • Identify and assess fraud-related risks;
  • Implement reasonable preventive and detective controls;
  • Define internal responsibilities for fraud monitoring and escalation;
  • Support regulated partners in meeting applicable anti-fraud requirements.

This Policy applies to:

  • All employees, contractors, officers, and representatives of Aigen;
  • Business users of the ItIsPay platform and APIs;
  • All activities conducted through ItIsPay-branded services, interfaces, and infrastructure.

2. Regulatory Positioning and Role of the Company

Aigen LLC is a technology and software service provider operating under the ItIsPay brand.

Aigen:

  • Is not a bank, electronic money institution (EMI), payment institution (PI), or virtual asset service provider (VASP);
  • Does not provide regulated financial services in its own name;
  • Does not hold client funds or customer assets.

Where regulated financial services are required, such services are provided solely by licensed third-party financial institutions, acting under their own regulatory authorizations and contractual frameworks.

Aigen’s role is limited to providing technical infrastructure, integrations, and operational tooling in support of such regulated services.

3. Definition of Fraud

For the purposes of this Policy, fraud means any intentional act or omission designed to obtain an unlawful or dishonest benefit through deception, concealment, manipulation, or misrepresentation.

Fraud may include, without limitation:

  • Manipulation or abuse of payment or settlement processes;
  • Falsification, alteration, or misuse of records or data;
  • Misappropriation of fiat or digital assets;
  • Bribery, corruption, or improper inducements;
  • Identity misuse or impersonation;
  • Circumvention of compliance, monitoring, or risk controls;
  • Collusion between parties to evade safeguards.

4. Fraud Risk Categories

4.1 Identity-Related Fraud

Non-exhaustive examples include:

  • First-party fraud;
  • Second-party fraud;
  • Synthetic identity fraud;
  • Third-party impersonation;
  • Account takeover.

4.2 Transactional and Operational Fraud

  • Abuse of APIs or automated workflows;
  • Structuring or layering of transactions;
  • Use of the platform for prohibited or deceptive purposes;
  • Attempts to bypass partner compliance or monitoring rules.

5. Fraud Detection and Monitoring

Potential fraudulent activity may be identified through:

  • Automated system alerts and anomaly detection;
  • Notifications from regulated partners;
  • Internal monitoring and periodic reviews;
  • Third-party intelligence or reports;
  • User complaints or internal referrals.

Aigen maintains reasonable technical and organizational measures to detect suspicious or anomalous behavior within the scope of its services.

6. Investigations and Escalation

Upon identification of suspected fraud:

  1. An internal assessment is conducted by the Compliance function;
  2. Relevant logs, records, and data are preserved;
  3. The matter is escalated, where applicable, to the relevant regulated partner;
  4. Legal counsel may be consulted depending on jurisdiction and severity.

Investigations are conducted impartially, without regard to seniority, tenure, or relationship status.

7. Relationship Termination and Restrictions

Where fraudulent activity is confirmed or reasonably suspected, Aigen may:

  • Restrict, suspend, or terminate access to ItIsPay services;
  • Terminate contractual relationships;
  • Notify regulated partners or competent authorities where required by law or contract.

Any such actions are taken in accordance with applicable law and contractual obligations.

8. Cooperation with Authorities and Partners

Aigen cooperates in good faith with:

  • Licensed financial institutions and regulated partners;
  • Competent regulatory authorities acting within their jurisdiction;
  • Law enforcement agencies where legally required.

All disclosures are subject to applicable confidentiality, data protection, and privacy laws.

9. Training and Awareness

Aigen promotes internal awareness of fraud risks and provides appropriate guidance to employees and contractors regarding fraud prevention, detection, and escalation.

Where relevant, Aigen also supports partners in understanding fraud risks associated with the use of its technology.

10. Reporting Suspected Fraud

Suspected fraud may be reported to Aigen via:

Email: [email protected]

Reports should include, where available:

  • A description of the suspected activity;
  • Relevant dates, identifiers, or references;
  • Supporting documentation or evidence.

11. Policy Review

This Anti-Fraud Policy is reviewed periodically and updated as necessary to reflect:

  • Changes in applicable laws or regulations;
  • Evolution of fraud risks;
  • Changes in Aigen’s business model or partnerships.

The current version is published on the ItIsPay website.

12. No Waiver

Failure to enforce any provision of this Policy does not constitute a waiver of Aigen’s right to enforce such provision in the future.