1. Our Commitment
Nevoxe Pay, Inc. is committed to the highest standards of Anti-Money Laundering ("AML") and Counter-Terrorism Financing ("CTF") compliance. We recognize that cryptocurrency payment infrastructure can be exploited for financial crime if proper controls are not implemented. Our AML/CTF program is designed to prevent, detect, and report money laundering, terrorist financing, and other financial crimes.
Our program is built on four pillars:
- Prevention: Robust customer due diligence (CDD) and Know Your Customer (KYC) controls before onboarding.
- Detection: Continuous blockchain analytics and behavioral monitoring to identify suspicious activity.
- Reporting: Timely filing of Suspicious Activity Reports (SARs) with competent authorities.
- Governance: Board-level accountability, a designated Compliance Officer, and regular independent audits.
2. Scope & Applicability
This policy applies to:
- All merchants and users of the Nevoxe Pay platform, regardless of jurisdiction
- All employees, contractors, and agents of Nevoxe Pay, Inc.
- All cryptocurrency transactions processed through our infrastructure
- All API integrations and downstream payment flows initiated through our APIs
Merchants integrating Nevoxe Pay are required to implement their own AML/KYC controls for their end customers and to cooperate fully with our compliance requests. By using our Services, merchants attest that they will not process funds for prohibited activities or on behalf of sanctioned persons.
3. Customer Due Diligence (CDD)
3.1 Standard Due Diligence (SDD)
Applied to all merchants at onboarding. Includes:
- Identity verification (government-issued ID, liveness check)
- Proof of address verification
- Screening against global sanctions lists (OFAC, EU, UN, FATF high-risk jurisdictions)
- PEP (Politically Exposed Persons) screening
- Adverse media screening
3.2 Enhanced Due Diligence (EDD)
Applied to higher-risk customers, including:
- High-volume merchants (monthly processing above defined thresholds)
- Businesses in higher-risk sectors (gambling, adult content, firearms — where permitted by law)
- Customers from FATF-listed high-risk or monitored jurisdictions
- Politically Exposed Persons (PEPs) and their close associates
- Corporate structures with complex ownership chains
EDD may include source of wealth declarations, enhanced business due diligence, reference checks, and senior management approval for onboarding.
3.3 Simplified Due Diligence (SDD)
Applied to certain regulated entities (licensed financial institutions, listed companies) where the risk of money laundering is demonstrably low. Requires verification of regulated status and license details.
3.4 Business KYC (KYB)
For merchant entities, we collect and verify:
- Certificate of Incorporation or equivalent
- Memorandum and Articles of Association
- Register of directors and shareholders
- Ultimate Beneficial Owner (UBO) declarations — all persons owning or controlling 25% or more
- Identity verification for all UBOs and directors
- Proof of operating address
- License or regulatory approval where applicable
4. Risk-Based Approach
We apply a risk-based approach to AML/CTF compliance, allocating more intensive due diligence resources to higher-risk customers and transactions. Our risk scoring model considers:
- Customer Risk: Jurisdiction of incorporation/residence, business type, ownership structure, PEP status, adverse media, and historical activity.
- Transaction Risk: Cryptocurrency type, transaction size, frequency, velocity, counterparty wallet risk scores (blockchain analytics), and deviation from expected patterns.
- Geographic Risk: Countries subject to FATF grey-listing, EU high-risk third-country designation, or OFAC comprehensive sanctions programs.
- Channel Risk: Direct API integration vs. third-party connector; self-custodied wallets vs. exchange-held wallets.
Risk scores are reviewed periodically and upon significant changes in a customer's profile or transaction behavior.
5. Transaction Monitoring
We deploy automated blockchain analytics powered by leading chain analysis providers to screen all transactions for:
- Wallet addresses associated with sanctioned entities, darknet markets, ransomware wallets, or terrorism financing
- Funds originating from or destined to mixers, tumblers, or high-risk exchanges
- Structuring (breaking large transactions into smaller amounts to avoid reporting thresholds)
- Unusual transaction velocity, volume spikes, or round-number patterns
- Layering patterns indicative of fund laundering
Alerts generated by our monitoring systems are reviewed by our compliance team. Transactions presenting unacceptable risk may be blocked, and associated accounts may be suspended pending investigation.
6. Sanctions Screening
Nevoxe Pay screens all customers, beneficial owners, and counterparty wallet addresses against the following sanctions lists in real time:
- OFAC (Office of Foreign Assets Control) — Specially Designated Nationals (SDN) List
- European Union Consolidated Sanctions List
- United Nations Security Council Consolidated List
- UK Financial Sanctions Lists (OFSI)
- FATF High-Risk and Other Monitored Jurisdictions
Positive matches result in immediate transaction blocking and account restriction. We do not provide services to sanctioned persons, entities, or jurisdictions under any circumstances. Circumvention of sanctions controls through corporate structures or nominees will result in permanent account termination and reporting to relevant authorities.
7. Suspicious Activity Reporting
Where we identify activity that we suspect or know involves the proceeds of criminal conduct or terrorism financing, we are legally obligated to file a Suspicious Activity Report (SAR) or equivalent with the competent financial intelligence unit (FIU) in the relevant jurisdiction. We are prohibited by law from "tipping off" the subject of an SAR that a report has been made.
Associated funds may be frozen pending regulatory direction. Nevoxe Pay cooperates fully with law enforcement and regulatory investigations, including the provision of transaction records, KYC documentation, and API logs pursuant to valid legal process.
If you are a financial institution or regulated entity with a legitimate compliance inquiry, contact our Compliance team at compliance@nevoxepay.com.
8. Prohibited Jurisdictions
We do not provide services to persons, entities, or transactions having a nexus to jurisdictions subject to comprehensive United Nations, EU, or OFAC sanctions programs, currently including:
- Islamic Republic of Iran
- Democratic People's Republic of Korea (North Korea)
- Republic of Cuba
- Syrian Arab Republic
- Crimea Region of Ukraine (Russian-occupied)
- Donetsk and Luhansk People's Republics (Russian-occupied regions of Ukraine)
- Any other jurisdiction subsequently added to applicable sanctions programs
Additionally, enhanced scrutiny is applied to transactions involving FATF grey-listed and black-listed jurisdictions. This list is reviewed quarterly.
9. Record Keeping
In accordance with applicable AML legislation, we retain:
- KYC documents and identity verification records: minimum 5 years from the end of the customer relationship
- Transaction records: minimum 5 years from the date of the transaction (7 years in certain jurisdictions)
- Internal compliance reports, SAR filings, and investigation notes: 5 years
- Staff training records: 3 years
All records are stored encrypted, access-controlled, and available for production to regulators upon lawful request.
10. Training & Governance
10.1 Compliance Officer
A designated Compliance Officer (MLRO — Money Laundering Reporting Officer) is responsible for the day-to-day operation of our AML/CTF program, SAR filings, liaison with regulators, and the annual AML risk assessment.
10.2 Staff Training
All employees with exposure to customer-facing or transaction-processing functions receive AML/CTF training upon onboarding and at least annually thereafter. Training covers red flag indicators, internal reporting procedures, and legal obligations.
10.3 Independent Audit
Our AML/CTF program is subject to independent review at least annually to assess the effectiveness of controls, identify gaps, and ensure alignment with evolving regulatory requirements.
11. FATF Travel Rule
In compliance with the Financial Action Task Force (FATF) Recommendation 16 (the "Travel Rule") and its implementation in applicable jurisdictions, Nevoxe Pay collects, holds, and transmits required originator and beneficiary information for virtual asset transfers that meet or exceed the applicable threshold.
For qualifying transfers, we collect:
- Originator name and account number (wallet address)
- Originator physical address, national identity number, or date and place of birth
- Beneficiary name and account number (wallet address)
We utilize Travel Rule-compliant messaging protocols to transmit this information securely to receiving Virtual Asset Service Providers (VASPs) where technically feasible.
12. Compliance Contact
For AML/compliance inquiries, law enforcement requests, or to report suspected financial crime:
- Compliance Team: compliance@nevoxepay.com
- Legal: legal@nevoxepay.com
- Security / Fraud: security@nevoxepay.com
Law enforcement requests should be submitted in accordance with our Law Enforcement Guidelines, available upon request.