KYC & AML Policy

CardToU  (“CardToU”, “we”, “us”, “our”, and Company) has developed an Anti-Money Laundering and Anti-Terrorist Financing Policy (“AML Policy”) to ensure compliance with applicable laws and regulations concerning anti-money laundering and terrorist financing. Our policies and procedures exceed legislative requirements in the US and demonstrate our commitment to managing money laundering and terrorist financing risks effectively.

The Proceeds of Crime and Terrorist Financing Act:

In compliance with the legislative requirements outlined in the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“PCMLTFA”), our Company adheres to various record-keeping, identification, and reporting obligations. Our compliance regime includes:

• Establishment of robust internal policies, procedures, and controls to prevent the illicit use of CardToU’s products or services.
• Implementation of Know Your Customer (“KYC”) procedures on all customers* to meet PCMLTFA requirements.
• Assessment of risks related to money laundering and terrorist financing.
• Adherence to record retention requirements mandated by the PCMLTFA.
• Monitoring transactions for suspicious activities and filing Suspicious Transaction Reports (“STR”) or Attempted Suspicious Transaction Reports (“ASTR”) as necessary.
• Provision of ongoing compliance training for employees to ensure understanding of their responsibilities under the PCMLTFA and US Regulations.
• Regular reviews of our compliance regime every two years to assess effectiveness in combating money laundering and terrorist financing.

Ongoing Monitoring of Business Relationships:

A business relationship is established when a client holds an account with our organization. At CardToU, an active account, and thus a business relationship, is defined by a customer conducting two or more commercial transactions (excluding closed loop gift card purchases) within a 12-month period. Therefore, for business relationships, CardToU must:

• Verify the identity of the individual.
• Risk-rate all business relationships and adjust ratings as necessary.
• Conduct ongoing monitoring based on the assigned risk rating (high/low).
• Maintain records of measures taken to monitor the relationship and obtained information.

If necessary, we may request additional documentation or information from customers to confirm the source of funds for transactions. Our system employs automated and manual monitoring procedures with an escalation process based on risk. Any transactions triggering system alerts are reviewed by CardToU’s compliance staff to ensure consistency with stated activity and normal usage behavior before completion. In some cases, customers may be asked to provide additional information such as identity documents or payment receipts.

Know Your Customer Processes:

Prior to a transaction using CardToU’s products or services, we must identify the customer through Know Your Customer (“KYC”) processes in accordance with applicable regulations. Our policy requires all customers to be “verified” under the following circumstances:

Information collected to verify and authenticate a customer or beneficial owner may include:

• Email address.
• Mobile phone number.
• Full legal name.
• IP Address.
• Unique device information.
• Proof of identity or passport.
• Additional information or documentation at the discretion of our compliance team.

If unexplainable or unusual patterns or activity are identified during review and monitoring, we work to obtain further information to address concerns. CardToU may report suspicious activity internally to our CCO and may file a Suspicious Transaction Report (“STR”) with the appropriate regulatory authorities if necessary.

Failure to reach a clear understanding of a customer’s identity or the sources and movement of funds may result in account closure, termination of the business relationship, and blacklisting of the account owner to prevent them from opening a new account.

If you have any questions or concerns, please contact info@cardtou.com.