AML/KYC Policy

Cenoa maintains a risk-based Anti-Money-Laundering and Know-Your-Customer (AML/KYC) program designed to comply with the U.S. Bank Secrecy Act, the EU's Anti-Money-Laundering Directives, the FATF Recommendations, and other applicable financial-crime laws. The program is overseen by a designated Compliance Officer who reports to executive management and the board.

Before opening an account or providing certain services, we collect and verify identifying information about every customer (and beneficial owners for business accounts). We use third-party identity verification, document inspection, and database checks. Account features and limits depend on the level of verification completed.

For higher-risk customers (including politically exposed persons, customers in high-risk jurisdictions, and customers in elevated-risk industries), we apply additional scrutiny including source-of-funds inquiries, ongoing review, and senior-management approval. We may decline to onboard or continue serving customers who present unacceptable risk.

All transactions are monitored in real time and on an ongoing basis using a combination of rule-based scenarios, machine-learning models, and analyst review. Alerts are investigated by trained personnel; suspicious activity may result in additional questions, transaction holds, account restrictions, or filings with authorities.

We screen customers, beneficial owners, and counterparties against U.S. OFAC, UN, EU, UK, and other applicable sanctions lists at onboarding and continuously thereafter. We do not knowingly provide services to sanctioned persons or to customers in comprehensively sanctioned regions.

We file Currency Transaction Reports, Suspicious Activity Reports, and equivalent reports with FinCEN and other competent authorities as required by law. Cenoa does not notify customers when a report has been filed.

We retain customer-identification records, transaction records, and SAR-related records for at least five years (or longer where required by local law).

All Cenoa personnel complete AML training at hire and at least annually thereafter. Compliance, risk, and customer-facing teams receive role-specific training.

Compliance inquiries can be directed to compliance@cenoapayments.com. Law enforcement requests should be sent to legal@cenoapayments.com.