AML/KYC

1. Introduction

This Anti-Money Laundering (AML) & KYC Policy outlines Cointivo’s commitment to preventing money laundering, terrorist financing, sanctions violations, fraud, and other financial crimes, including, but not limited to, activities prohibited under applicable local and international laws.

Cointivo operates as a privacy-focused cryptocurrency exchange. We do not conduct routine or blanket identity verification. Our compliance framework is strictly risk-based and focused on detecting and preventing high-risk or unlawful activity while protecting legitimate users.

2. Privacy-Focused Framework

Cointivo does not require mandatory KYC for deposits, trading, withdrawals within published limits.

Users may use the platform freely within these limits, provided funds are not classified as High-Risk Funds (as defined below) and no legal obligation requires enhanced due diligence.

There is no routine KYC, no random identity checks, and no surprise verification for normal trading activity.

3. Right to Withdraw

If a deposit is completed and not restricted following automated risk screening, the user retains the right to withdraw their funds, subject to platform limits and applicable law.

Cointivo does not freeze or restrict legitimate funds without a defined legal or compliance basis, including, but not limited to, sanctions obligations, court orders, or confirmed High-Risk classifications.

4. Risk-Based Monitoring

We employ advanced monitoring systems, including blockchain analytics tools and sanctions screening, to detect exposure to unlawful activity, including, but not limited to, terrorist financing, sanctioned individuals or entities, stolen or hacked funds, state-sponsored theft, court-ordered asset freezes, government seizure directives, darknet marketplace exposure, cryptocurrency mixers, obfuscation services.

5. Classification of Funds

5.1 Abnormal Funds

Abnormal Funds refer to deposits associated with elevated transactional risk, including, but not limited to, darknet marketplaces, cryptocurrency mixers, obfuscation services, high-risk marketplaces.

If such funds are detected, the deposit may be blocked from trading, the user will be notified, the user may withdraw the funds to a wallet they control, and no mandatory KYC is required solely for refunding Abnormal Funds.

Abnormal Funds remain the property of the user and are always eligible for withdrawal back to a self-controlled address.

5.2 High-Risk Funds

High-Risk Funds are assets associated with serious legal or regulatory exposure, including, but not limited to, terrorist financing, confirmed sanctions matches, stolen or hacked assets, assets flagged by competent authorities, court-ordered freezes or seizures.

If funds are classified as High-Risk, access may be restricted, assets may be frozen, additional review may occur, and Cointivo may comply with applicable legal obligations.

6. When KYC May Be Required

Cointivo does not impose routine KYC requirements.

KYC may be required only where legally necessary or in response to confirmed High-Risk exposure, including, but not limited to, a verified sanctions match, a valid law enforcement request, a court order, confirmed stolen funds, confirmed terrorist financing exposure.

KYC is not triggered by normal trading, lawful withdrawals within limits, legitimate profit generation, or routine platform usage.

7. No Shotgun KYC Guarantee

Cointivo does not engage in “shotgun KYC” practices. We do not request identity verification without a defined legal, regulatory, or confirmed High-Risk basis.

Identity verification will never be imposed arbitrarily, retroactively, or solely due to trading success, withdrawal activity within limits, or lawful platform usage.

If you deposit lawful funds and your activity does not involve High-Risk Funds, you are not subject to forced identity verification.

Our compliance controls are narrowly tailored and targeted exclusively at unlawful activity, including, but not limited to, terrorist financing, sanctions violations, and stolen asset exposure.

8. Ownership of Assets

Users retain ownership of digital assets deposited on Cointivo, subject to applicable law, sanctions regulations, judicial orders, and government directives.

If funds are not classified as High-Risk Funds, users may trade and withdraw freely within platform limits.

9. Prohibited Activities

The following activities are strictly prohibited on the platform, including, but not limited to, money laundering or attempted money laundering, terrorist financing, transactions involving sanctioned individuals or entities, use of stolen or hacked funds, circumventing compliance controls.

10. Reservation of Rights

Cointivo reserves the right to restrict or suspend accounts, block or delay transactions, request additional information where legally required, modify withdrawal limits, comply with legal or regulatory obligations, including, but not limited to, situations involving High-Risk Funds or government directives.

These measures are applied in a targeted, risk-based manner and not arbitrarily.

11. Policy Updates

This Policy may be updated periodically to reflect changes in law, regulation, operational requirements, or risk environment, including, but not limited to, AML or sanctions framework developments.

Continued use of the platform constitutes acceptance of the current version of this Policy.