AML & KYC
notice.

STATUS · DRAFT · PENDING LICENSING
EFFECTIVE · ON LAUNCH
LICENCE · TO BE CONFIRMED
MLRO · [email protected]

01Overview

CoinMoove operates a risk-based, regulator-aligned AML programme. We screen, we monitor, we report, and we cooperate with authorities. We expect the same diligence from our merchants.

This notice summarises the controls and obligations governing our anti-money-laundering, counter-terrorist-financing, sanctions, and Travel Rule programmes. It applies to all CoinMoove merchants and is supplemental to the Terms of Service.

02Regulatory regime

CoinMoove will operate as a registered virtual-asset service provider in its jurisdiction of incorporation. The specific national licence, regulator, and registration number will be published in this section ahead of public launch. Once operational, CoinMoove will be subject to:

  • EU AML Directive (Directive 2015/849, as amended).
  • EU Travel Rule Regulation (Regulation (EU) 2023/1113).
  • EU Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114) — phased application 2024–2026.
  • FATF Recommendations, including Recommendation 16 (the "Travel Rule").
  • EU restrictive measures and UN Security Council sanctions.

03Customer due diligence (CDD)

Standard CDD

For all merchants we collect and verify:

  • Legal entity name, registration number, country of incorporation.
  • Articles of association and proof of registration.
  • Identity documents and proof of address of beneficial owners (≥25% interest) and directors.
  • Description of business activities, expected volume, source of funds.
  • Where applicable, evidence of licences or authorisations required for the business.

Enhanced due diligence (EDD)

EDD applies where any of the following is present: high-risk jurisdiction, politically-exposed persons (PEPs), complex ownership, cash-intensive business, or anomalous transaction patterns. EDD includes additional source-of-wealth evidence, senior-management approval, and ongoing enhanced monitoring.

Simplified CDD

Available in limited circumstances for low-risk, regulated counterparties (e.g., licensed credit institutions), subject to documented justification.

04Transaction monitoring

Every inbound and outbound transaction is screened in real time. We use Chainalysis KYT and TRM Labs scoring to assess counterparty risk. Indicators include:

  • Direct or indirect exposure to sanctioned addresses.
  • Mixer, tumbler, and privacy-coin interactions.
  • Dark-market and ransomware addresses.
  • Structuring patterns and rapid pass-through.
  • Anomalies relative to the merchant's declared volume and customer base.

Transactions exceeding our risk threshold are paused for human review by a Level-2 analyst. Cleared transactions are released; escalated transactions may be returned to source or reported to the FIU as a suspicious activity report (SAR).

05Travel Rule

For transfers exceeding €1,000 (single transaction or aggregated within 24 hours), we collect and transmit:

  • Originator name, account, address, ID number, or date and place of birth.
  • Beneficiary name and account.

We participate in the TRP Travel Rule Protocol and the IVMS-101 data standard. Where the counterparty VASP is not on our supported networks, we will request the information directly and may delay settlement pending receipt.

06Sanctions screening

We screen all merchants, beneficial owners, counterparties, and wallet addresses against:

  • EU Consolidated Financial Sanctions List.
  • UN Security Council sanctions.
  • OFAC Specially Designated Nationals (SDN) and Sectoral Sanctions Identifications (SSI).
  • UK HM Treasury Office of Financial Sanctions Implementation (OFSI).
  • Additional national lists where applicable.

Screening is performed using established commercial sanctions and PEP databases, refreshed in near real time. Specific vendor partners will be named in this section ahead of public launch.

07Reporting

Suspicious activity is reported to the competent Financial Intelligence Unit in our jurisdiction of incorporation within the statutory deadline (typically 2 business days of detection), or sooner where required. We do not (and may not, by law) disclose to merchants that a report has been made.

Threshold reports (cash-equivalent transactions, cross-border transfers) are filed in accordance with national requirements in each market we serve.

08Restricted jurisdictions

We do not onboard merchants resident or registered in jurisdictions subject to comprehensive sanctions, FATF blacklisting, or where local law prohibits the services. The list is reviewed monthly and currently includes:

  • Comprehensively sanctioned: Iran, North Korea, Syria, Cuba, the Crimea, Donetsk, Luhansk, Zaporizhzhia, and Kherson regions of Ukraine.
  • FATF blacklist: North Korea, Iran, Myanmar.
  • Other restricted: Russia (sectoral restrictions), Belarus (sectoral restrictions).
  • United States residents and entities: serviced only through our authorised US partner once licensing is complete (currently in progress).

09Audit & governance

Our AML programme is overseen by a Board-appointed Money Laundering Reporting Officer (MLRO) reporting directly to the Board. The programme is independently audited annually by a Big Four or equivalent firm; the most recent attestation is available to merchants under NDA on request once we exit closed beta. Internal staff complete AML training quarterly.

10Contact MLRO

For AML enquiries, source-of-funds questions, or formal information requests:

Money Laundering Reporting Officer · CoinMoove
[email protected] · PGP available on request