AML/CFT Policy

Nodela is committed to preventing financial crime and maintaining a secure payment infrastructure globally.

Last updated: March 2026

# 1. Introduction

Nodela is a digital payment infrastructure platform that enables merchants and businesses to accept cryptocurrency payments from customers globally. As part of operating a responsible financial technology platform, Nodela is committed to preventing the misuse of its services for money laundering, terrorist financing, fraud, and other forms of financial crime. This Anti‑Money Laundering and Counter‑Financing of Terrorism (AML/CFT) Policy establishes the internal framework used by Nodela to detect, prevent, and respond to suspicious activity on its platform.

# 2. Regulatory Philosophy

Although Nodela may operate in jurisdictions where direct regulatory licensing is not required for its core infrastructure services, the company adopts global best practices for financial compliance. The company aligns its internal controls with internationally recognized standards and recommendations issued by global financial crime prevention bodies and industry compliance frameworks.

# 3. Scope of Policy

This policy applies to all employees, contractors, systems, technology infrastructure, and partners involved in the operation of the Nodela platform.

The policy governs:

  • Customer onboarding procedures
  • Merchant verification processes
  • Transaction monitoring practices
  • Suspicious activity identification
  • Internal compliance responsibilities

# 4. Risk‑Based Compliance Approach

Nodela follows a risk‑based approach to compliance. This means the level of monitoring and due diligence applied to users or transactions depends on the risk profile associated with them.

Risk is evaluated using several indicators including:

  • Geographic risk
  • Business industry risk
  • Transaction volume
  • Transaction behavior
  • Blockchain exposure risk

Higher risk profiles require stronger monitoring and verification procedures.

# 5. Customer Risk Categories

Customers and merchants on the platform are classified into risk categories.

Low Risk:

Small businesses or individuals conducting normal commerce with low transaction volumes.

Medium Risk:

Businesses operating in sectors with moderate exposure to financial risk or increased transaction activity.

High Risk:

Entities operating in industries historically associated with higher financial crime risk or customers located in high‑risk jurisdictions.

# 6. Transaction Monitoring

Nodela implements automated and manual transaction monitoring processes to detect suspicious or unusual patterns.

Examples of monitored activity include:

  • Rapid transaction repetition
  • Large or unusual payment sizes
  • Interaction with blockchain addresses linked to illicit activity
  • Structuring transactions to avoid monitoring thresholds

Monitoring systems analyze blockchain data and platform behavior to identify irregular activity.

# 7. Sanctions Screening

Nodela screens users, merchants, and counterparties against internationally recognized sanctions lists where applicable. These checks may occur during onboarding as well as periodically during the life of the account. Screening ensures the platform does not facilitate transactions involving restricted persons, entities, or jurisdictions.

# 8. Suspicious Activity Investigation

When suspicious activity is detected, the compliance team performs an internal investigation. This may include reviewing transaction data, account history, and associated blockchain activity.

If risk indicators remain unresolved, actions may include:

  • Temporary account restriction
  • Additional verification requests
  • Transaction blocking
  • Reporting to partners or relevant authorities when required.

# 9. Record Keeping

Nodela maintains records related to user verification, compliance monitoring, and transaction activity for a reasonable period consistent with international financial compliance standards. Maintaining historical records enables the company to investigate potential issues and cooperate with financial institutions or regulatory bodies when necessary.

# 10. Employee Responsibilities

All employees and contractors are expected to understand and comply with this AML/CFT policy. Personnel working in operational, engineering, and support roles must report any unusual or suspicious activity observed on the platform to the designated compliance contact.

# 11. Compliance Officer

Nodela designates a compliance officer responsible for maintaining the AML/CFT program.

Responsibilities include:

  • Overseeing implementation of compliance controls
  • Monitoring regulatory developments
  • Coordinating internal investigations
  • Updating policies when required

# 12. Internal Training

Employees may receive periodic guidance or training on financial crime prevention, suspicious activity detection, and proper escalation procedures. The objective of training is to ensure staff understand the importance of maintaining a secure financial platform.

# 13. Technology Controls

Nodela relies on a combination of technology infrastructure and risk detection tools to maintain platform integrity.

These may include:

  • blockchain analytics tools
  • transaction monitoring systems
  • automated alerts for suspicious patterns

# 14. Cooperation With Partners

Nodela may cooperate with financial institutions, payment providers, compliance partners, and law enforcement agencies where legally required to prevent financial crime. Information may be shared with partners for the purpose of investigating suspicious transactions.

# 15. Policy Updates

This AML/CFT policy will be periodically reviewed and updated to reflect evolving regulatory requirements, technological developments, and risk environments.