AML / CFT / CPF Policy

Cloove (the “Company”) is committed to the highest standards of integrity and to full compliance with Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT), and Counter-Proliferation Financing (CPF) requirements in every market where we operate.

This policy sets out the framework we use to identify, assess, and mitigate the risk that our platform could be used to launder the proceeds of crime, finance terrorism, or finance the proliferation of weapons of mass destruction.

This policy applies across all of Cloove’s operations and to:

• All employees, contractors, officers, and directors.
• All merchants, customers, and business partners on the platform.
• All products and services, including wallets, payments, and payouts.
• All third-party payment processors and vendors acting on our behalf.

Ultimate responsibility for Cloove’s AML/CFT/CPF programme sits with the Board of Directors. The Board appoints a Money Laundering Reporting Officer (MLRO) with day-to-day responsibility for:

We apply a Risk-Based Approach (RBA) so that our resources are focused where the risk is greatest. Every merchant is assigned a risk rating - low, medium, or high - based on factors including:

Know Your Customer (KYC) is the foundation of our programme. We apply Customer Due Diligence (CDD) proportionate to the risk a relationship presents, across three levels:

Cloove uses AI-driven transaction-monitoring systems to detect suspicious patterns in real time. Indicators we monitor for include:

• Structuring (smurfing) and layering of funds.
• Unusual cross-border activity.
• Rapid movement of funds (high velocity).
• Reactivation of dormant accounts.
• Matches against sanctioned entities.
• Activity that does not fit the declared merchant category.

Where suspicious activity is detected and confirmed through investigation, Cloove files a Suspicious Activity Report (SAR) - or Suspicious Transaction Report - with the relevant authorities, in line with local and international law.

Cloove adheres strictly to economic and trade sanctions programmes. We screen all merchants and transaction counterparties against:

• United Nations Security Council sanctions lists.
• OFAC (U.S. Department of the Treasury) lists.
• European Union consolidated sanctions lists.
• Applicable domestic and local watchlists.

We maintain controls to prevent the financing of the proliferation of weapons of mass destruction (WMD), including:

In line with regulatory requirements, Cloove retains comprehensive records - covering customer identification, transactions, and compliance investigations - for no less than five (5) years after a business relationship ends. These records include:

• Customer identification and verification documents.
• Account-opening files and related correspondence.
• Detailed records of all transactions processed.
• Internal suspicious-activity reports and MLRO determinations.

All relevant staff complete mandatory, regular AML/CFT/CPF training so they can recognise and respond to financial-crime risk.

To keep the programme effective, we run regular independent audits and internal reviews:

Findings are reported to the Board and used to strengthen our controls. Questions about this policy can be directed to compliance@clooveai.com.