AML & CTF Statement

1. Commitment

Universe Card is committed to preventing money laundering, terrorist financing and sanctions evasion. We operate our programme in line with the requirements of our partner card issuers and applicable law, and we support their regulatory obligations with full data cooperation.

2. Customer due diligence

• KYC/KYB before first use. Every account completes identity verification (individuals) or business verification including ultimate-beneficial-owner declarations (companies) before topping up or issuing cards.
• Screening. Applicants and UBOs are screened against sanctions lists and politically-exposed-person databases at onboarding and on an ongoing basis. Confirmed matches are declined; potential matches are held for analyst review and, where warranted, escalated to the MLRO.
• Risk rating. Accounts carry a risk rating (low/medium/high) that drives limits, allowed BIN scope and review frequency. Enhanced due diligence applies to high-risk accounts.

3. Ongoing monitoring

• Automated rules monitor velocity, declines, merchant-category attempts and spending patterns; rule hits raise alerts that analysts turn into cases.
• Large top-ups (over $100,000 or unusual for the account) trigger source-of-funds checks before or promptly after crediting.
• Bank transfers without a matching reference are held unmatched until manually reviewed and matched by an operations admin.
• Payouts pass maker-checker review including recipient screening before execution.

4. Prohibited customers and jurisdictions

We do not serve persons or entities subject to sanctions administered by the UN, EU, UK (OFSI) or US (OFAC), or residents of comprehensively sanctioned jurisdictions. We do not serve businesses whose activity falls under the prohibited categories of our Acceptable Use Policy. The full jurisdiction list is maintained with our Issuers and available on request: [jurisdiction list].

5. Records and reporting

Verification records, transaction data and case files are retained for at least five years after the business relationship ends. Suspicious activity is escalated internally to the MLRO and reported to the competent financial-intelligence unit where required. We may freeze balances, cards or payouts without prior notice where the law or an Issuer requires it, and we may be prohibited from telling you why ("no tipping-off").

6. Governance

Administrative access to compliance tooling is role-restricted (dedicated KYC-analyst and risk roles), protected by SSO with enforced multi-factor authentication, and every decision — approval, rejection, escalation, freeze — is written to an immutable audit log with the acting admin recorded. Money-moving actions require two people (maker-checker).

7. Contact

MLRO contact for authorities and partners: [MLRO name] · support@universecard.io