Anti-money Laundering Policy Risk Assessment

Purpose and Scope

9vgo implements an anti-money laundering (AML) program to prevent money laundering and the financing of terrorism across all products and services. This policy governs customer due diligence, transaction monitoring, data handling, and reporting requirements applicable to the 9vgo platform.

Regulatory Framework and Risk-Based Approach

9vgo complies with applicable anti-money laundering and counter-financing of terrorism laws. We apply a risk-based approach to customer due diligence, employing three levels of verification: Simplified Due Diligence (SDD) for negligible risk, Standard Due Diligence (CDD) for standard activity, and Enhanced Due Diligence (EDD) for high-risk profiles or large transactions. Determinations are made at account opening and reviewed on an ongoing basis.

Know Your Customer and Due Diligence Triggers

Due to regulatory requirements, 9vgo conducts identity and risk verification before enabling full service. Trigger points for mandatory KYC include: aggregate lifetime deposits exceeding EUR 5,000 or any withdrawal request from an unverified account. When triggered, the user must complete the full KYC process before transactions continue.

KYC Process and Documentation

Proof of Identity: Government-issued photo ID; signature where applicable; country of residence not in the restricted list; full name matching the account holder; document validity not expiring within the next three months; applicant must be at least 18 years old.
Proof of Residence: Recent bank statement or utility bill; name matches the account holder; address matching stated residence; issue date within the last three months; document issued from non-restricted jurisdictions.
Selfie with ID: Portrait photo of the user holding the same ID used for verification; ensures identity integrity.

Data Protection, Retention, and Access

Personal data collected by 9vgo is processed in accordance with applicable data protection laws, including GDPR. 9vgo is the data controller for personal information collected through the service. Personal data may be shared with service providers for identity verification, regulatory reporting, or as required by law, and with competent authorities upon request. Retention of personal information is eight (8) years from the end of the relationship or as otherwise required by law.

Transaction Monitoring and Suspicious Activity Reporting

All transactions are subject to ongoing automated and manual monitoring to identify unusual or suspicious activity. 9vgo maintains a record of transactions and related data for the retention period. If activity indicates potential money laundering or terrorist financing, we will report to the competent authorities and cooperate with official investigations in accordance with applicable laws.

Account Access, Restrictions, and Compliance

Access to certain services and features is conditioned on successful KYC verification. If verification is pending or unsuccessful, deposits, withdrawals, or other sensitive transactions may be restricted or suspended in accordance with applicable law and internal risk controls. We reserve the right to suspend or terminate accounts that fail to meet identification or ongoing due diligence requirements.

User Rights and Consent

Users may withdraw consent for data processing where lawful; withdrawal may affect our ability to provide the Services. To exercise rights, users may contact the compliance team at compliance@9vgo. Where processing is necessary for performance of a contract or for compliance with legal obligations, withdrawal will not affect the lawfulness of processing prior to withdrawal.

Policy Amendments and Effective Date

This AML policy supersedes prior versions. 9vgo reserves the right to amend this policy at any time. Continued use of the platform after an amendment constitutes acceptance of the revised policy.