AML/KYC

Last Updated: October 14, 2026

1. Introduction

Cointivo is committed to maintaining a secure, transparent, and compliant cryptocurrency trading environment. We adopt a zero-tolerance approach toward money laundering, terrorist financing, sanctions evasion, fraud, financial exploitation, and other illicit financial activities.

This Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) Policy establishes the compliance standards applicable to users accessing Cointivo's products and services.

Cointivo implements mandatory customer identity verification, risk-based transaction monitoring, blockchain analytics, sanctions screening, and enhanced due diligence procedures to protect its users, financial infrastructure, and the broader digital asset ecosystem.

Our compliance framework is designed to align with applicable laws and regulations, relevant international sanctions requirements, and recognized standards established by the Financial Action Task Force (FATF).

2. Mandatory Know Your Customer (KYC) Verification

All customers must successfully complete Cointivo's mandatory identity verification process before accessing cryptocurrency deposits, withdrawals, spot trading, conversions, and other applicable financial products.

Depending on the customer's profile, jurisdiction, and assessed risk, verification may include:

• Full legal name, date of birth, nationality, and residential address.
• Valid government-issued identity document.
• Facial recognition, biometric verification, or liveness detection.
• Verification of identity document authenticity.
• Screening against applicable sanctions lists, politically exposed person (PEP) databases, and relevant adverse media.
• Additional documentation establishing source of funds, source of wealth, or beneficial ownership where required.

Cointivo may request further information or conduct additional verification when necessary to meet legal obligations or internal risk management standards.

Customers who fail to complete mandatory verification, provide false information, or attempt to circumvent verification procedures may be denied access to Cointivo's services.

3. Ongoing Customer Due Diligence

Identity verification is not limited to account registration. Cointivo performs ongoing customer due diligence throughout the business relationship to ensure customer information remains accurate, transactions are consistent with expected activity, and emerging compliance risks are identified.

Additional verification may be required in circumstances including, but not limited to:

• Significant changes in transaction patterns or account behavior.
• Unusual or unexplained deposits, withdrawals, or trading activity.
• Exposure to high-risk jurisdictions or counterparties.
• Potential identity theft, account compromise, or impersonation.
• Inconsistencies in previously submitted customer information.
• Changes in applicable regulatory requirements.
• Detection of suspicious transactions or blockchain exposure.

Cointivo reserves the right to periodically update customer information and request renewed identity documentation where justified.

4. Risk-Based Monitoring and Blockchain Analytics

Cointivo employs automated and manual compliance controls designed to identify suspicious activities and potential financial crime.

These controls may include blockchain analytics, wallet risk screening, transaction monitoring, device intelligence, behavioral analysis, sanctions screening, and fraud detection systems.

Monitoring may identify exposure to:

• Sanctioned individuals, organizations, wallet addresses, and jurisdictions.
• Terrorist financing and proliferation financing.
• Stolen, hacked, or fraudulently obtained digital assets.
• Ransomware payments and cybercrime-related transactions.
• Darknet marketplaces and illicit trading platforms.
• Cryptocurrency mixers, tumblers, and obfuscation services.
• Fraudulent investment schemes, phishing, and financial scams.
• Unlicensed or otherwise prohibited financial services.
• Unusual transaction patterns and attempts to evade compliance controls.

A risk indicator does not automatically establish wrongdoing. Cointivo evaluates relevant information, including the nature, severity, reliability, and context of detected risks, before determining appropriate action.

5. Classification of Funds and Transactions

Cointivo applies a risk-based classification framework to deposits, withdrawals, wallet addresses, and other relevant transactions.

5.1 Standard-Risk Funds

Standard-Risk Funds are digital assets for which screening and monitoring have not identified material risk indicators requiring further investigation.

These funds may be deposited, traded, converted, or withdrawn in accordance with applicable verification requirements, account limits, platform rules, and legal obligations.

5.2 Elevated-Risk Funds

Elevated-Risk Funds are assets associated with unusual transactional behavior, insufficiently explained activity, indirect exposure to higher-risk services, or other indicators warranting additional review.

Examples may include exposure to cryptocurrency mixers, high-risk exchanges, unidentified counterparties, or complex transaction patterns.

Cointivo may temporarily delay processing, restrict affected transactions, request additional information, conduct enhanced due diligence, or reject a transaction where appropriate.

Where legally permissible, Cointivo may return funds to a verified originating source or another approved destination following compliance review.

Returns are not automatic or guaranteed. Any return or withdrawal remains subject to applicable laws, sanctions restrictions, ownership verification, fraud prevention requirements, and the outcome of relevant investigations.

5.3 High-Risk or Prohibited Funds

High-Risk or Prohibited Funds include digital assets reasonably suspected or confirmed to be connected with serious financial crime or legal restrictions, including:

• Sanctions violations or dealings with sanctioned parties.
• Terrorist financing or proliferation financing.
• Stolen or hacked cryptocurrency.
• Ransomware or cybercrime proceeds.
• Money laundering or proceeds of unlawful activity.
• Assets subject to judicial orders, seizure requests, or legally binding restrictions.

Where justified or legally required, Cointivo may suspend transactions, restrict account access, block withdrawals, preserve relevant records, freeze assets where legally authorized or obligated, or refer matters to competent authorities.

Such measures will be implemented in accordance with applicable law and Cointivo's internal compliance procedures.

6. Enhanced Due Diligence (EDD)

Cointivo may apply Enhanced Due Diligence to customers, transactions, or relationships presenting elevated money laundering, terrorist financing, sanctions, or fraud risks.

EDD measures may include:

• Requesting supporting evidence of source of funds or source of wealth.
• Verifying employment, business activities, or economic purpose.
• Reviewing transaction histories and wallet ownership.
• Evaluating exposure to high-risk jurisdictions and counterparties.
• Conducting additional identity and beneficial ownership verification.
• Obtaining additional internal compliance approval.
• Applying increased transaction monitoring or appropriate account restrictions.

Failure to provide satisfactory information may result in transaction rejection, account suspension, or termination of the business relationship.

7. Sanctions Compliance

Cointivo maintains a sanctions compliance framework designed to prevent prohibited transactions and relationships.

Depending on applicable legal obligations and Cointivo's internal risk policies, screening may incorporate sanctions measures issued by:

• United Nations Security Council.
• United States Office of Foreign Assets Control (OFAC).
• European Union.
• United Kingdom Office of Financial Sanctions Implementation (OFSI).
• Other applicable national and international sanctions authorities.

Cointivo may restrict access from prohibited jurisdictions and may reject or block transactions involving sanctioned persons, entities, or assets.

Attempts to evade geographic restrictions, conceal beneficial ownership, or circumvent sanctions controls are strictly prohibited.

8. Deposits, Withdrawals, and Account Restrictions

All deposits and withdrawals are subject to applicable identity verification, blockchain screening, transaction monitoring, and security controls.

Cointivo may delay, reject, or restrict transactions where reasonably necessary to investigate suspicious activity, verify ownership, prevent fraud, protect customer assets, or comply with legal obligations.

• A completed blockchain deposit does not guarantee immediate availability for trading or withdrawal.
• Withdrawal requests may be subject to additional security or compliance review.
• Cointivo may require verification of the originating or receiving wallet.
• Assets connected with potential fraud, sanctions exposure, or unlawful activity may be restricted pending further review.
• Funds subject to legally binding restrictions will not be released contrary to applicable law.

Cointivo aims to avoid unnecessary or disproportionate restrictions on legitimate customer funds. However, it does not guarantee unrestricted access where compliance or security concerns remain unresolved.

9. Fraud Prevention and Account Security

Cointivo implements preventive controls to detect and mitigate fraud, including account takeover, identity theft, social engineering, investment scams, phishing, and unauthorized transactions.

These controls may include monitoring of device information, IP addresses, session activity, login behavior, transaction anomalies, and account security events.

Customers may be required to complete additional authentication or security verification when potentially unauthorized activity is detected.

Cointivo may temporarily restrict account access or transactions to prevent suspected fraud or protect customer assets.

10. Prohibited Activities

Cointivo strictly prohibits the use of its platform for unlawful or abusive financial activity, including, but not limited to:

• Money laundering, terrorist financing, or proliferation financing.
• Sanctions evasion or dealings with prohibited individuals and entities.
• Use, transfer, or concealment of stolen or fraudulently obtained assets.
• Cryptocurrency scams, ransomware, phishing, or cybercrime.
• Identity fraud, impersonation, or submission of fraudulent documents.
• Use of third-party accounts or identities without authorization.
• Structuring transactions to evade monitoring, reporting, or verification requirements.
• Attempts to bypass account restrictions, geographic controls, or transaction monitoring.
• Any other activity prohibited by applicable law or Cointivo's Terms of Service.

Cointivo may refuse or terminate services involving prohibited activity and take any additional action required by law.

11. Suspicious Activity Reporting and Cooperation with Authorities

Cointivo maintains procedures for identifying, investigating, documenting, and escalating potentially suspicious activities.

Where legally required, Cointivo may submit suspicious activity reports, preserve transaction records, respond to lawful information requests, and cooperate with competent regulatory, judicial, or law enforcement authorities.

Cointivo may be legally prohibited from informing customers of certain investigations, reports, or disclosure requests.

Information will be shared only where permitted or required by applicable law and in accordance with relevant privacy and data protection obligations.

12. Protection of Customer Data and Privacy

Cointivo recognizes the importance of customer privacy and responsible handling of personal information.

KYC documents, financial records, account information, and compliance-related data are processed for legitimate purposes, including identity verification, regulatory compliance, fraud prevention, and platform security.

Cointivo applies appropriate administrative, technical, and organizational safeguards designed to prevent unauthorized access, disclosure, alteration, or misuse of personal data.

Information is retained for periods required by applicable law and legitimate operational requirements.

Customer information is not disclosed to unauthorized third parties, except where necessary for lawful processing, contracted compliance services, or legally permitted or required disclosures.

13. Recordkeeping and Compliance Controls

Cointivo maintains records necessary to support its compliance obligations, including identity verification results, relevant transaction records, compliance decisions, and investigations.

Records are retained in accordance with applicable legal requirements and internal retention policies.

Cointivo periodically reviews its compliance framework and may update its internal monitoring rules, procedures, technology, and risk assessment methodologies.

14. Customer Responsibilities

Customers are responsible for providing accurate, complete, and up-to-date information and for using Cointivo's services lawfully.

Customers must not provide misleading identity details, act on behalf of undisclosed third parties, conceal the origin of digital assets, or attempt to circumvent compliance measures.

Customers are expected to cooperate with reasonable verification and compliance requests.

Failure to comply may result in restrictions, suspension, rejection of transactions, or termination of services.

15. Reservation of Rights

Cointivo reserves the right, subject to applicable law, to:

• Reject account registrations or verification applications.
• Request additional KYC or EDD documentation.
• Restrict, delay, or reject transactions.
• Adjust account or transaction limits.
• Suspend or terminate accounts presenting unacceptable compliance risks.
• Freeze or restrict assets where legally authorized or required.
• Cooperate with competent authorities.
• Introduce or modify compliance controls where necessary.

Decisions are based on applicable legal obligations, documented risk assessments, relevant security considerations, and Cointivo's internal compliance framework.

16. Policy Updates

Cointivo may amend this Policy to reflect changes in applicable law, regulatory requirements, industry standards, operational processes, and identified compliance risks.

The latest version will be published through Cointivo's official website.

Continued use of Cointivo's services following the effective date of an updated Policy constitutes acceptance to the extent permitted by applicable law.

Cointivo is committed to maintaining a trustworthy digital asset trading environment through mandatory KYC, effective AML controls, responsible financial crime prevention, and the protection of legitimate customers.