Last updated: 19 May 2026
This policy describes how ExCards detects, prevents, and reports activity that may involve money laundering, terrorism financing, or sanctions evasion. It applies to all card issuance, top-up, and transaction flows.
ExCards and our card issuer partner apply customer due diligence (CDD) proportional to risk. Higher-risk indicators — jurisdiction, transaction patterns, source of funds — trigger enhanced due diligence (EDD).
Identity verification at card issuance includes a passport scan and basic personal details. We do not store biometric data. The issuer partner conducts independent CDD against international watchlists (UN, EU, OFAC, HM Treasury).
For high-value top-ups or unusual patterns, we may request documentation on the source of the USDT funds (exchange, wallet origin, salary, business revenue). Failure to provide reasonable documentation results in transaction rejection.
All card top-ups and card-based transactions are monitored in real time for: structuring (deposits just below reporting thresholds), velocity anomalies, high-risk merchant categories, geographic anomalies, and known sanctioned addresses.
Every customer and counterparty is screened against current sanctions lists (UN, EU, US OFAC SDN, UK HMT, Swiss SECO). Cards issued to or used by sanctioned persons are immediately blocked without refund.
Suspicious activity is reported to the relevant financial intelligence unit (FIU) of the card issuer's jurisdiction. We cooperate with lawful information requests from regulators and law enforcement.
AML-related records (CDD documents, transaction logs, suspicious activity reports) are retained for at least five years after the end of the customer relationship, in line with FATF Recommendation 11.
ExCards personnel with access to customer data receive periodic AML training. A designated AML compliance officer supervises the program.
This policy is reviewed annually and updated when regulatory expectations change. Material updates are announced via app.excards.io.
AML-related inquiries: /contact.html.