Anti-Money Laundering (AML) Policy

Last updated: March 2025 • Binding on all CardFi users and transactions

CardFi is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance. This policy outlines our obligations and your responsibilities as a user.

1. Our Commitment

CardFi Technologies Inc. maintains a comprehensive AML/CTF compliance programme designed to prevent our platform from being used for money laundering, terrorist financing, or other financial crimes. We adhere to international standards including FATF (Financial Action Task Force) recommendations and applicable local regulations.

2. Prohibited Activities

The following activities are strictly prohibited on the CardFi platform:

Depositing funds derived from illegal sources (drug trafficking, fraud, theft, corruption)
Structuring transactions to avoid reporting thresholds ("smurfing")
Using the platform to finance terrorism or terrorist organisations
Using false or stolen identities to open accounts
Layering funds through multiple accounts or transactions to disguise origins
Using CardFi to transact on behalf of sanctioned individuals or entities
Conducting transactions that appear designed to evade law enforcement detection

3. Know Your Customer (KYC) Requirements

All CardFi users are subject to KYC verification. This includes:

Identity Verification: Government-issued photo ID (passport, national ID, driver's licence)
Proof of Address: Utility bill or bank statement (less than 3 months old)
Selfie Verification: Live photo with ID document
Enhanced Due Diligence (EDD): Additional checks for high-risk users or large transactions

Failure to complete KYC will result in account restrictions and inability to transact above basic limits.

4. Transaction Monitoring

CardFi employs automated and manual transaction monitoring systems to detect suspicious activity. We monitor for:

Unusually large or rapid deposits/withdrawals
Transactions inconsistent with declared account purpose or user profile
Multiple transactions just below reporting thresholds
Patterns suggesting layering or structuring
Transactions involving high-risk jurisdictions or sanctioned addresses
Unusual card spending patterns

5. Sanctions Screening

CardFi screens all users and transactions against major sanctions lists, including:

OFAC (US Treasury Office of Foreign Assets Control)
EU Consolidated Sanctions List
UN Security Council Sanctions List
HM Treasury (UK) Financial Sanctions
Local jurisdiction sanctions as applicable

Accounts or transactions matching sanctions lists will be immediately frozen and reported to relevant authorities.

6. Suspicious Activity Reporting

Where CardFi identifies suspicious activity, we are obligated by law to:

File Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) with relevant financial intelligence units
Freeze the relevant account pending investigation
Cooperate fully with law enforcement requests
Not disclose ("tip off") the user that a report has been filed

7. Record Keeping

CardFi retains all transaction records, KYC documents, and correspondence for a minimum of 5 years (or longer if required by jurisdiction) to support regulatory investigations and audits.

8. Staff Training

CardFi staff involved in compliance, customer support, and operations receive regular AML/CTF training to identify red flags and understand their reporting obligations.

9. Cooperation with Authorities

CardFi will cooperate fully with law enforcement agencies, financial intelligence units, and regulatory bodies. We will provide records and information as required by valid legal process.

10. User Obligations

As a CardFi user, you agree to:

Only deposit funds from legitimate sources
Provide accurate and complete information during KYC
Promptly respond to any requests for additional documentation
Not assist any third party in using CardFi for prohibited purposes
Report any suspicious activity you become aware of to compliance@cardfi.online

11. Consequences of Non-Compliance

Violation of this AML Policy may result in:

Immediate account suspension or permanent termination
Freezing of account balance pending investigation
Reporting to law enforcement and financial intelligence units
Legal action where applicable

12. Contact Compliance Team

For AML/compliance enquiries, contact our dedicated compliance team at compliance@cardfi.online.