1. Purpose and Scope
This Anti-Money Laundering ("AML") Policy outlines the procedures and controls Trusttocard maintains to detect, prevent, and report suspicious activity. The policy applies to users, partners, and processes involved in providing card services.
2. Regulatory Framework
Trusttocard seeks to comply with applicable AML/CTF requirements in jurisdictions where our services are offered, including FATF approaches, AMLD rules, sanctions regimes, and payment partner requirements.
- Financial Action Task Force (FATF) recommendations;
- EU Anti-Money Laundering Directives;
- OFAC, EU, UN, and local sanctions lists;
- payment and compliance partner requirements.
3. Risk-Based Approach
We assess risks associated with users, products, wallets, delivery channels, geography, and transaction types. Higher-risk scenarios may be subject to enhanced due diligence.
4. Customer Due Diligence
Users must connect a compatible non-custodial wallet. Blockchain analytics may be used to assess the risk profile of wallet addresses, including transaction history and associations with illicit activity.
4.1 Enhanced Due Diligence
For high-value transactions or accounts flagged by monitoring systems, additional information may be requested, including proof of source of funds.
5. Transaction Monitoring
Trusttocard uses automated and manual monitoring processes to identify suspicious activity.
- unusual transaction patterns or volumes;
- transactions involving high-risk jurisdictions;
- structuring or attempts to circumvent limits;
- interactions with addresses associated with sanctions or criminal activity;
- rapid fund movement inconsistent with the user's profile.
6. Sanctions Compliance
Users and transactions may be screened against applicable sanctions lists. Services are not available to sanctioned individuals, entities, or prohibited jurisdictions.
7. Suspicious Activity Reporting
Where there are reasonable grounds to suspect money laundering or terrorist financing, Trusttocard may submit appropriate reports to competent authorities or partner compliance teams as required by law.
8. Record Keeping
We retain records related to user identification, transactions, and AML reports for the period required by applicable law and partner policies.
9. Training
Personnel and contractors involved in compliance processes receive regular AML training covering suspicious activity indicators and internal reporting procedures.
10. Compliance Officer and Policy Review
The designated AML Compliance Officer oversees the implementation of this policy. This policy is reviewed at least annually or more frequently when regulations, risks, or internal procedures change.
For AML-related inquiries, contact compliance@trusttocard.com.