Transaction Monitoring Policy

Last updated: March 2025

CardFi monitors all transactions in real-time to detect and prevent financial crime, fraud, and misuse of our platform. This policy explains how our monitoring works and what it means for you as a user.

1. Purpose

Transaction monitoring is a key component of CardFi's AML/CFT programme. Our monitoring systems are designed to:

Detect suspicious patterns that may indicate money laundering or financial crime
Identify unusual activity that deviates from a user's expected behaviour
Ensure compliance with applicable financial regulations
Protect users from unauthorised use of their accounts
Generate alerts for human review when automated rules are triggered

2. What We Monitor

Our monitoring systems analyse all transaction activity on the CardFi platform, including:

USDT deposits (amount, frequency, source address)
Withdrawal requests (amount, destination, timing)
Virtual card transactions (merchant category, geography, amount)
Account login patterns and device fingerprints
KYC document submission patterns
Referral and promotional activity

3. Automated Alert Triggers

Our systems automatically flag transactions based on rule-based and behavioural analytics. Common triggers include:

Single transaction exceeding $1,000 USDT (unverified accounts)
Multiple rapid transactions in a short time period
Transactions just below reporting thresholds (structuring indicators)
Deposits from or withdrawals to high-risk blockchain addresses (OFAC-listed, mixer-associated)
Sudden change in transaction volume inconsistent with user history
Transactions involving high-risk jurisdictions
Card usage in unusual geographies or multiple countries simultaneously

4. Blockchain Analytics

CardFi uses blockchain analytics tools to assess the risk of incoming cryptocurrency transactions. We check:

Whether source wallet addresses are associated with known illicit activity
Exposure to sanctions-listed addresses
Association with cryptocurrency mixers or tumbling services
Dark web marketplace associations

Deposits from high-risk addresses may be held pending review or returned to sender.

5. Investigation Process

When a transaction is flagged:

The transaction or account may be temporarily restricted
Our compliance team reviews the alert within 1–3 business days
We may contact you to request additional information or documentation
If cleared, restrictions are lifted and the transaction is processed
If not cleared, the account may be suspended and funds held pending investigation
Confirmed suspicious activity is reported to relevant authorities

6. Account Holds and Freezes

CardFi reserves the right to:

Place a temporary hold on transactions pending review
Freeze an account if suspicious activity is detected
Require enhanced KYC documentation before releasing held funds
Refuse to process specific transactions without explanation (as permitted by law)

7. Reporting Obligations

Where our investigation confirms suspicious activity, we are legally obligated to:

File Suspicious Activity Reports (SARs) with relevant financial intelligence units
Not disclose to the user that a SAR has been filed ("tipping off" prohibition)
Cooperate with law enforcement investigations
Retain all relevant records for regulatory review

8. Your Cooperation

In the event your account is under review, we ask that you:

Respond promptly to any requests for information
Provide documentation as requested (source of funds, purpose of transaction)
Not attempt to circumvent monitoring controls

Failure to cooperate may result in permanent account closure and reporting to authorities.

9. Contact

For queries related to transaction monitoring or account holds, contact our compliance team at compliance@cardfi.online.