Legal

AML Policy for CashCows

Last updated: May 22, 2026

1. Purpose

This Anti-Money Laundering ("AML") Policy establishes the framework implemented by CashCows to prevent, detect, and mitigate risks associated with:

  • Money laundering
  • Terrorist financing
  • Fraud
  • Sanctions violations
  • Financial crime
  • Illicit use of digital assets and payment systems

CashCows is committed to maintaining a compliant and risk-based AML program in accordance with applicable laws, regulations, and industry best practices.

2. Scope

This AML Policy applies to:

  • All users of the CashCows platform
  • Fiat payment transactions
  • Cryptocurrency transactions
  • Apple Pay and card transactions
  • Internal employees and contractors
  • Third-party service providers where applicable

3. Compliance Objectives

CashCows aims to:

  • Prevent the use of the platform for financial crime
  • Identify and verify customer identities
  • Monitor transactions for suspicious activity
  • Comply with sanctions regulations
  • Maintain records required by law
  • Cooperate with competent authorities
  • Reduce fraud and chargeback risk

4. Risk-Based Approach

CashCows applies a risk-based compliance framework.

User risk assessments may consider:

  • Jurisdiction
  • Transaction size
  • Payment method
  • Cryptocurrency wallet activity
  • Source of funds
  • Behavioral indicators
  • Device/IP information
  • Politically exposed person ("PEP") status
  • Adverse media exposure

Enhanced due diligence may apply to higher-risk users.

5. Customer Identification Program (KYC)

CashCows requires Know Your Customer ("KYC") verification before users may access certain platform features or conduct transactions.

Verification measures may include:

  • Government-issued identification
  • Selfie/liveness verification
  • Proof of address
  • Source of funds documentation
  • Ongoing identity reviews

CashCows reserves the right to:

• Reject incomplete verification

• Request additional documents

• Suspend accounts pending verification

• Restrict platform access

KYC requirements apply regardless of whether users pay with credit/debit cards, Apple Pay, bank transfers, or cryptocurrency.

6. Sanctions Screening

CashCows conducts sanctions screening against applicable lists, which may include:

  • OFAC sanctions lists
  • EU sanctions lists
  • UK sanctions lists
  • UN sanctions lists

Users located in restricted or sanctioned jurisdictions may be prohibited from using the platform.

CashCows reserves the right to block accounts, freeze transactions, reject payments, or restrict access where sanctions concerns exist.

7. Politically Exposed Persons (PEPs)

CashCows may identify and monitor politically exposed persons ("PEPs") and their associates.

Enhanced due diligence measures may apply to:

  • PEPs
  • Family members of PEPs
  • Close associates
  • High-profile public officials

8. Transaction Monitoring

CashCows monitors transactions for suspicious or unusual activity.

Monitoring activities may include:

  • Large or unusual transfers
  • Structuring behavior
  • High-risk jurisdictions
  • Rapid movement of funds
  • Multiple payment methods
  • Suspicious wallet activity
  • Mixer/tumbler interaction
  • Fraud indicators
  • Abnormal transaction velocity

Transactions may be delayed, reviewed, rejected, or reported where necessary.

9. Cryptocurrency Monitoring

CashCows may utilize blockchain analytics and wallet screening tools to assess cryptocurrency-related risks.

Monitoring may include:

  • Sanctioned wallet screening
  • Mixer/tumbler detection
  • Darknet exposure analysis
  • Fraud risk analysis
  • Blockchain tracing

CashCows reserves the right to reject or restrict cryptocurrency transactions deemed high-risk.

10. Source of Funds & Enhanced Due Diligence

CashCows may require users to provide documentation demonstrating the lawful origin of funds.

Examples may include:

  • Bank statements
  • Payslips
  • Tax documents
  • Business records
  • Asset sale documentation
  • Crypto transaction records

Enhanced due diligence ("EDD") may apply where heightened risk is identified.

11. Suspicious Activity Reporting

CashCows reserves the right to investigate suspicious activity and report transactions to competent authorities where required.

Users acknowledge that:

  • Transactions may be delayed during investigations
  • Accounts may be restricted or suspended
  • Information may be disclosed to regulators or law enforcement

CashCows may act without prior notice where legally required.

12. Record Retention

CashCows may retain AML/KYC records for periods required by applicable law.

Stored information may include:

  • Identity documents
  • Transaction records
  • Wallet information
  • Communication logs
  • Compliance reviews
  • Risk assessments

13. Restricted Activities

Users may not use CashCows for:

  • Money laundering
  • Terrorist financing
  • Fraudulent activity
  • Sanctions evasion
  • Illegal gambling
  • Illicit goods/services
  • Unauthorized financial activity
  • Use of stolen payment methods

CashCows reserves the right to terminate accounts involved in prohibited conduct.

14. Third-Party Providers

CashCows may utilize third-party providers for:

  • KYC verification
  • AML screening
  • Blockchain analytics
  • Fraud prevention
  • Payment processing
  • Transaction monitoring

Third-party providers may process user information in accordance with applicable laws and agreements.

15. Internal Controls

CashCows maintains internal compliance procedures including:

  • Access controls
  • Audit logging
  • Employee monitoring
  • Compliance escalation procedures
  • Fraud prevention systems
  • Security reviews

16. Policy Updates

CashCows reserves the right to modify this AML Policy at any time to reflect:

  • Regulatory changes
  • Operational updates
  • Evolving risk environments
  • Industry standards

Updated versions become effective upon publication.

17. Contact Information

Compliance-related inquiries may be directed to:

compliance@cashcows.com