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AML and identity checks

Prepaid credit can be misused to move money. This is what MUSTER does about it: who we refuse, what the product will not do, what we ask for and when, and what we keep.

Last updated25.09.2026Contactthe contact form
  1. A01Why a platform selling eSIMs has this policy at all
  2. A02What the product will not do, by design
  3. A03Countries we cannot serve
  4. A04What we check, and when
  5. A05When we refuse, hold or close
  6. A06Records and reporting
  7. A07Questions about this policy

Contents

  1. A01Why a platform selling eSIMs has this policy at all
  2. A02What the product will not do, by design
  3. A03Countries we cannot serve
  4. A04What we check, and when
  5. A05When we refuse, hold or close
  6. A06Records and reporting
  7. A07Questions about this policy
A01

Why a platform selling eSIMs has this policy at all

MUSTER holds prepaid credit. Anything that holds a balance for someone and lets them spend it later can, in principle, be used to move value rather than to buy the thing it sells. This page says plainly what we do about that, so you can see the checks before you meet one.

We are not a bank, a payment institution or an electronic money institution, and we do not hold your money on deposit. Credit is prepayment for eSIMs and coordinator time on this platform, nothing more. Your card payment is taken by a regulated card processor, which runs its own anti-money-laundering checks on top of ours.

A02

What the product will not do, by design

MUSTER is built with these limits:

  • Card payments only. Visa and Mastercard, through our card processor, with 3-D Secure. No cash, no bank transfers into an account balance, no cryptocurrency, no vouchers, no other card schemes.
  • Credit cannot be sent to another person. There is no transfer between accounts and no way to pay a third party out of a trip budget. Credit is spent on eSIMs and coordinator bookings on the account that bought it.
  • Money only goes back where it came from. Unused credit is refunded to the card that paid for it, in the currency you paid in — never to a different card, account or person. The refund policy sets out when.
  • A ceiling on every payment. The largest single top-up is €20,000, checked on our server and not only in the form. See the payment policy.

Together these mean credit on MUSTER is a poor instrument for moving money: it can only be spent here, and it can only come back to the card that bought it.

A03

Countries we cannot serve

We do not open accounts for people living in, or organisations established in, a comprehensively sanctioned jurisdiction. Today that means Belarus, Cuba, Iran, North Korea, Russia, Syria. The country list on the sign-up form does not offer these countries, and the server refuses them again if one is submitted another way.

This follows EU and international sanctions and is not a decision we can review case by case. It applies to the country the organiser lives in or, when they act for an organisation, the country that organisation is established in. You may still buy eSIMs for travel to countries we cover; where a traveller goes is a different question from where the buyer is based, and the terms also forbid use for travellers established in a sanctioned jurisdiction.

A04

What we check, and when

WhenWhat we check
You open an accountThe country you live in, or the one your organisation is established in, against the refused list above. Your email address, so we can reach the account holder.
You top upOur card processor runs its own fraud and sanctions screening and applies 3-D Secure. We record the amount, the result and a payment reference.
A pattern looks wrongRepeated top-ups followed by refund requests without eSIMs being issued, payments from several unrelated cards, or a balance that is loaded and unloaded rather than spent. We may then ask for identification before allowing a further payment or a refund.
Someone applies to the coordinator deskA copy of a government identity document and the bank details for their payouts. Nobody is approved, and no payout is made, before the desk has reviewed both.

We do not ask a normal organiser for identity documents to buy eSIMs. We ask only in the situations named above, and we say why when we ask.

A05

When we refuse, hold or close

We may refuse a payment, hold a refund or close an account when:

  • The organiser lives in, or their organisation is established in, a refused country;
  • Identification we have asked for is not given, or does not match the account;
  • The card processor declines the payment on its own checks;
  • We have reasonable grounds to think the account is being used to move money rather than to buy eSIMs and coordinator time.

Where the law allows us to explain, we do. Where it does not, we will say only that we cannot proceed. Closing an account does not take your credit: unused credit is returned to the card it came from, unless we are legally prevented from returning it.

A06

Records and reporting

Ledger entries, payment records and booking records are kept for six years after the transaction, as the privacy policy sets out. A coordinator's identity document is kept in our database, never at a public link, and only desk staff can open it.

If we are required by the law of the Republic of Estonia or by a competent authority to report a transaction or to freeze an account, we will do so, and we may be forbidden from telling you that we have. We will never invent a reason to cover that; we will simply not comment.

A07

Questions about this policy

Write to us on the contact form. If we have asked you for identification and you want to know exactly why, ask on the same form and we will tell you as far as the law allows. Complaints about a decision follow the route in the refund policy.

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Muster

eSIMs for every traveller on a group trip, generated in one go and tracked on a live install board.

Tsernskin keiys OÜ
P. Kerese tn 17-20, 20309 Narva, Ida-Viru maakond, Estonia
Registry code 17587191
Registered in Estonia
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