2.1 The programme is designed with reference to applicable laws and recognised standards, including FATF recommendations and jurisdiction‑specific AML rules (including travel rule requirements where applicable).

3.1 ARGOcoin (Core Services). Responsible for:

• KYC/CDD onboarding, verification, risk scoring, and ongoing monitoring;
• sanctions/PEP screening and blockchain transaction monitoring;
• holds/freezes and suspicious activity assessments for Core transactions;
• travel rule compliance for Core transfers.

3.2 Vowallex / Card Issuer (Card Services). Responsible for:

• card programme eligibility checks, cardholder onboarding flows as applicable;
• card fraud controls, issuer and scheme rule compliance;
• disputes/chargebacks intake and routing.

3.3 User obligations. Users must provide accurate information, cooperate with verification requests, and comply with Terms and Policies.

4.1 We apply a risk‑based approach considering:

• customer type (individual/business), geography, PEP exposure,
• transaction patterns and value,
• product features (custody, exchange, card use, ATM access),
• source of funds/wealth indicators,
• adverse media and typologies.

4.2 Higher risk results in Enhanced Due Diligence (EDD) measures.

5.1 Individuals – baseline. We may collect:

• name, DOB, nationality, residence,
• ID document(s),
• selfie/liveness check where used,
• proof of address depending on tier and risk.

5.2 Businesses (KYB). We may collect:

• incorporation documents, registry extracts,
• ownership structure, UBOs, directors,
• business address, nature of business,
• source of funds/wealth, purpose of account.

5.3 Ongoing CDD. We may refresh documents and information periodically or when triggers occur.

EDD may include:

• additional identity evidence,
• source of funds/wealth corroboration,
• senior management approval,
• transaction limits, monitoring intensification,
• enhanced screening frequency.

7.1 We screen customers (and where relevant UBOs) against sanctions and PEP lists and apply geofencing and restricted jurisdiction controls.

7.2 We may block or restrict services where there is a match or high‑risk indicator.

8.1 For Core Services, ARGOcoin monitors transactions for suspicious patterns and blockchain risk indicators (e.g., sanctioned exposure, mixer exposure, darknet links).

8.2 For Card Services, card programme participants apply card fraud monitoring and scheme rule controls.

9.1 Where required, we collect and transmit originator and beneficiary information for virtual asset transfers.

9.2 Transfers may be delayed or rejected if required information is missing or unverifiable.

10.1 We may:

• restrict accounts and transactions,
• request additional documents,
• file reports with competent authorities where required,
• cooperate with law enforcement under legal process.

11.1 We maintain records in accordance with Applicable Law and retention obligations (often 5–10 years for AML).

12.1 Use of Services for ML/TF, sanctions evasion, fraud, ransomware, trafficking, WMD proliferation financing, or other criminal activity is prohibited.

13.1 Failure to provide requested information may lead to restrictions, suspension, or termination.

14.1 This Policy may be updated.

14.2 Core compliance contact: [email protected]. General: contact [AT] owncrypto.io.