Anti-Money Laundering and Counter-Terrorist Financing Policy

CCTRX maintains a risk-based AML / CTF programme aligned with the FATF recommendations, the EU AMLD framework, the UK MLR 2017 (as amended), and the standards of our card-issuing partners and acquiring banks. The programme is owned by our Money Laundering Reporting Officer (MLRO), reviewed annually, and approved by the board.

We do not knowingly facilitate money laundering, terror financing, sanctions evasion, fraud, or any predicate offence.

Every user completes electronic KYC before being able to deposit, hold a balance, or spend on a card. CDD includes: collection of identifying information; authentication of a government-issued identity document; biometric liveness comparison; sanctions, PEP and adverse-media screening; and assessment of country and product risk.

Corporate customers complete KYB including identification of beneficial owners holding 25 % or more, directors, and controllers, with supporting incorporation and good-standing documentation.

EDD is applied to: politically exposed persons and their close associates; customers resident in or transacting with higher-risk jurisdictions; users whose on-chain or card activity exceeds our risk thresholds; and any case where we have a reasonable suspicion of unusual activity.

EDD measures include source-of-funds and source-of-wealth documentation, senior-management approval, and ongoing monitoring with reduced thresholds.

All on-chain deposits are screened against blockchain-analytics risk scores before being credited. Deposits originating from mixers, sanctioned addresses, darknet markets, ransomware, fraud, child-exploitation or similarly tainted clusters are blocked and reported.

Card transactions are monitored in real time and post-settlement for patterns indicative of structuring, layering, fraud, scheme abuse, money muling, or sanctions evasion. Alerts are reviewed by trained analysts and escalated to the MLRO where appropriate.

We screen customers, beneficial owners, deposit addresses, and counterparties against the OFAC SDN, EU Consolidated, UK HMT, UN Security Council, and other applicable lists at onboarding, at every material change, and on a continuous basis. We do not service sanctioned persons or entities and we block transactions involving sanctioned addresses.

Where we identify activity that we know, suspect, or have reasonable grounds to suspect involves the proceeds of crime or the financing of terrorism, we file a Suspicious Activity Report (SAR) with the competent Financial Intelligence Unit. We do not, and are not permitted to, tip off the subject of a SAR.

KYC files, transaction records, SAR documentation, and decision logs are retained for at least 5 years after the end of the customer relationship, and longer where required.

All staff complete AML / CTF training on hire, annually thereafter, and ad hoc when material regulatory changes occur. Customer-facing and risk staff receive role-specific training.

The MLRO reports to the board, maintains the policy and risk assessment, oversees alerts and SARs, and serves as the point of contact with regulators. The programme is subject to independent review at appropriate intervals.

Concerns about a possible breach of this policy can be raised confidentially with compliance@cctrx.com.