AML / CFT / CPF
Policy

Cloove AI (the Company) is committed to the highest standards of integrity and compliance with Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT), and Counter-Proliferation Financing (CPF) regulations.

This policy outlines our framework for identifying, assessing, and mitigating the risks of money laundering, terrorist financing, and the financing of weapons of mass destruction proliferate. We operate under a strict Zero Tolerance policy for financial crime.

This policy applies to all operations of Cloove AI globally, including:

• All employees, contractors, and directors.
• Global platform merchants and business partners.
• All products, including wallets and payments.
• Third-party payment processors and vendors.

Responsibility for Cloove's AML/CFT/CPF program lies with the Board of Directors. The Board has appointed a Money Laundering Reporting Officer (MLRO) who has primary responsibility for:

• Strategic Oversight

  Developing and maintaining the AML/CFT/CPF framework.

• Regulatory Liaison

  Acting as the main point of contact for Financial Intelligence Units (FIUs).

• Operational Control

  Supervising the investigation of suspicious activities.

• Continuous Monitoring

  Reviewing the efficacy of our compliance tech stack.

We utilize a Risk-Based Approach (RBA) to ensure that our resources are focused on the highest risks. Every merchant is assigned a Risk Level (Low, Medium, High) based on:

Know Your Customer (KYC) is the foundation of our compliance program. We perform three levels of CDD:

Cloove employs advanced AI-driven transaction monitoring systems to detect suspicious patterns in real-time, including:

• Structuring (Smurfing) / Layering
• Unusual cross-border activity
• Rapid movement of funds (Velocity)
• Dormant account reactivation
• Sanctioned entity matches
• High-risk merchant-category mismatches

When suspicious activity is detected and confirmed through investigation, Cloove will file a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) with the relevant local and international authorities.

Cloove strictly adheres to economic and trade sanctions programs administered by international bodies and domestic regulators. This includes mandatory screening of all merchants and transaction counterparties against:

• United Nations Security Council Sanctions
• OFAC (U.S. Department of Treasury)
• European Union Consolidated Lists
• Local Domestic Watchlists

Cloove maintains strict controls to prevent the financing of the proliferation of weapons of mass destruction (WMD). This includes:

In accordance with regulatory requirements, Cloove maintains comprehensive records of all customer identification data, transaction records, and compliance investigations for a period of no less than five (5) years after the business relationship has ended.

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

All relevant staff at Cloove undergo mandatory, regular training on AML/CFT/CPF compliance to ensure they are equipped to identify and respond to potential risks.

To ensure the ongoing effectiveness of our AML/CFT/CPF program, we conduct regular independent audits and internal reviews.