Last updated: [Insert date]

1. Purpose of This Policy

The purpose of this AML & KYC Policy is to ensure that CDG Project and all Codego Group entities operate in full compliance with applicable anti-money laundering (AML), counter-terrorism financing (CTF), fraud prevention, and customer due diligence (CDD) regulations. This policy is designed to prevent the use of CDG Devices, CDG tokens, IBAN and card services, and any related infrastructure for illicit activities.

2. Regulatory Obligations

Codego Group LTD and associated entities comply with:

  • EU Anti-Money Laundering Directives (AMLD5, AMLD6 and future updates)
  • FATF (Financial Action Task Force) recommendations
  • local AML/CTF laws and supervisory authority requirements
  • sanctions regimes (EU, UN, OFAC and others where applicable)
  • guidelines governing electronic money, crypto services and payment institutions

Certain services (IBAN accounts, cards, crypto exchange, device-based rewards) may also be regulated by partner institutions, which apply their own AML/KYC controls.

3. Customer Identification (KYC)

Before accessing certain services, users must undergo a mandatory Know Your Customer (KYC) process. This may include:

  • full name, date of birth, nationality and tax ID;
  • residential address verification;
  • government-issued ID or passport;
  • selfie liveness check or biometric verification;
  • proof of address documents;
  • source-of-funds or source-of-wealth declarations (where required);
  • additional due-diligence checks for high-risk jurisdictions.

Enhanced Due Diligence (EDD) applies to politically exposed persons (PEPs), sanctioned individuals, high-risk profiles or suspicious activity indicators.

4. Ongoing Monitoring

We continuously monitor interactions with CDG services to ensure compliance and detect potential misuse. This includes:

  • transaction monitoring (IBAN, card and crypto operations);
  • screening against sanctions lists and watchlists;
  • monitoring of CDG Device activity and behavioural anomalies;
  • automated risk scoring and enhanced reviews;
  • periodic KYC refresh for existing users.

5. Prohibited Activities

Users may not use CDG Devices, CDG tokens, the CDG Project app or related services for any illicit, unlawful or suspicious activity. Prohibited uses include, but are not limited to:

  • money laundering and terrorism financing;
  • sanctions evasion;
  • fraudulent or deceptive conduct;
  • use of stolen identities or synthetic identities;
  • child exploitation, human trafficking or related crimes;
  • ransomware payments or cybercrime operations;
  • illegal gambling or unlicensed financial activity;
  • transaction obfuscation using mixers, tumblers or privacy-enhancing techniques.

6. Reporting Suspicious Activities

Where required by law, Codego Group LTD and its regulated partners submit Suspicious Activity Reports (SARs) or equivalent notifications to the competent authorities. Users are not informed of such filings ("tipping-off" prohibition).

7. Data Processing for AML/KYC

Personal data collected for AML/KYC purposes is processed in accordance with our Privacy Policy and may be shared with:

  • regulated financial institutions;
  • KYC/AML verification providers;
  • fraud prevention and compliance partners;
  • regulatory or law-enforcement authorities where required by law.

Data is retained for the minimum period required by applicable AML regulations, typically between 5 and 10 years depending on jurisdiction.

8. User Responsibilities

Users must:

  • provide accurate and truthful information during onboarding;
  • update personal data when requested;
  • use CDG services only for lawful purposes;
  • cooperate with any compliance checks, audits or additional verification steps;
  • immediately report any suspicious activity or security concerns.

9. Refusal or Termination of Service

We may refuse to provide services or may suspend/terminate access if:

  • KYC verification cannot be completed;
  • fraudulent, misleading or inconsistent information is provided;
  • the user is identified as high-risk or appears on sanctions/PEP lists;
  • there is reasonable suspicion of illegal activity or policy violations;
  • required documentation is refused or repeatedly delayed.

10. Compliance of Partner Institutions

Certain services—such as card issuing, crypto exchange or IBAN accounts—are provided by external regulated partners. These partners apply their own AML/KYC frameworks and may request additional documentation or impose additional restrictions independently of us.

11. Changes to This Policy

We may update this AML & KYC Policy as legal requirements evolve or new services are launched. The updated version will be published on this page with a revised “Last updated” date.

12. Contact

For questions about this AML & KYC Policy or our compliance processes, contact:
support@cdgproject.com