AML Policy

Our commitment to preventing money laundering and maintaining financial integrity

Effective Date: January 1, 2025
Last Updated: January 1, 2025

1. Introduction

api-card is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines our procedures and controls to ensure compliance with applicable laws and regulations worldwide.

2. Regulatory Framework

Our AML program complies with relevant regulations including:

  • Bank Secrecy Act (BSA) and USA PATRIOT Act
  • EU Anti-Money Laundering Directives (AMLD)
  • Financial Action Task Force (FATF) recommendations
  • Local financial intelligence unit requirements
  • International sanctions and embargo laws

3. Customer Due Diligence (CDD)

3.1 Identity Verification

We verify customer identity through:

  • Government-issued photo identification
  • Proof of address verification
  • Date of birth confirmation
  • Beneficial ownership identification for entities
  • Enhanced due diligence for high-risk customers

3.2 Business Verification

For business accounts, we require:

  • Business registration documents
  • Articles of incorporation or equivalent
  • Beneficial ownership information
  • Business license and permits
  • Financial statements (when applicable)

4. Know Your Customer (KYC) Program

Our KYC program includes:

  • Customer Identification: Collecting and verifying customer information
  • Risk Assessment: Evaluating customer risk profiles
  • Ongoing Monitoring: Continuous transaction monitoring
  • Record Keeping: Maintaining comprehensive customer records
  • Reporting: Filing required regulatory reports

5. Risk-Based Approach

We categorize customers based on risk levels:

5.1 Low Risk

  • Individuals with established financial history
  • Businesses in low-risk jurisdictions
  • Standard transaction patterns
  • Transparent business activities

5.2 Medium Risk

  • New customers without established history
  • Cash-intensive businesses
  • Cross-border transactions
  • Higher transaction volumes

5.3 High Risk

  • Politically Exposed Persons (PEPs)
  • Customers from high-risk jurisdictions
  • Complex ownership structures
  • Unusual transaction patterns
  • Cryptocurrency exchanges and MSBs

6. Transaction Monitoring

We monitor transactions for suspicious activities including:

  • Unusual transaction amounts or frequencies
  • Structuring to avoid reporting thresholds
  • Transactions with no apparent business purpose
  • Rapid movement of funds
  • Transactions involving sanctioned parties
  • Cryptocurrency mixing or tumbling activities

7. Sanctions Screening

We screen all customers and transactions against:

  • OFAC Specially Designated Nationals (SDN) list
  • EU sanctions lists
  • UN Security Council sanctions lists
  • National sanctions and embargo lists
  • Law enforcement and regulatory watch lists

8. Suspicious Activity Reporting

We file Suspicious Activity Reports (SARs) when we detect:

  • Transactions that may involve money laundering
  • Terrorist financing activities
  • Violations of sanctions or embargoes
  • Fraud or other criminal activities
  • Structuring or other evasive behaviors

9. Record Keeping

We maintain comprehensive records including:

  • Customer identification and verification documents
  • Transaction records and supporting documentation
  • Risk assessments and due diligence files
  • Suspicious activity reports and investigations
  • Training records and compliance documentation

Records are retained for a minimum of 5 years, or longer as required by law.

10. Enhanced Due Diligence (EDD)

For high-risk customers, we implement EDD measures:

  • Senior management approval for account opening
  • Additional identity verification
  • Source of funds verification
  • More frequent monitoring and review
  • Ongoing relationship monitoring

11. Training and Awareness

Our AML training program includes:

  • Regular training for all employees
  • Specialized training for compliance staff
  • Updates on regulatory changes
  • Red flag identification training
  • Annual compliance certification

12. Third-Party Risk Management

We conduct due diligence on third-party service providers:

  • AML compliance assessment
  • Regulatory licensing verification
  • Ongoing monitoring of relationships
  • Contractual compliance obligations

13. Technology and Systems

Our AML technology infrastructure includes:

  • Automated transaction monitoring systems
  • Real-time sanctions screening
  • Risk scoring and analytics
  • Case management systems
  • Audit trails and reporting capabilities

14. Governance and Oversight

Our AML governance structure includes:

  • Board-level oversight and accountability
  • Designated AML Compliance Officer
  • Regular compliance committee meetings
  • Independent compliance testing
  • External audit and assessment

15. Prohibited Activities

We prohibit the following activities:

  • Money laundering in any form
  • Terrorist financing
  • Sanctions violations
  • Structuring transactions to avoid reporting
  • Processing transactions for prohibited businesses
  • Facilitating tax evasion

16. Reporting and Cooperation

We cooperate fully with law enforcement and regulatory authorities:

  • Timely filing of required reports
  • Response to information requests
  • Cooperation with investigations
  • Asset freezing and blocking when required

17. Contact Information

For AML compliance questions or to report suspicious activity:

  • Email:

This AML Policy is subject to regular review and updates to ensure continued compliance with evolving regulatory requirements.