AML/KYC Policy
Last updated: March 28, 2026
This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the procedures and controls that CCGO has established to detect, prevent, and report money laundering, terrorist financing, and other financial crimes. This policy applies to all users, employees, and partners of the CCGO platform.
1. Commitment to Compliance
CCGO is committed to maintaining the highest standards of anti-money laundering and counter-terrorism financing compliance. We adhere to applicable international and local regulations, including but not limited to:
- The Financial Action Task Force (FATF) recommendations.
- Hong Kong Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).
- The USA PATRIOT Act and Bank Secrecy Act (where applicable).
- European Union Anti-Money Laundering Directives.
- Visa and Mastercard compliance programs and network rules.
CCGO has appointed a designated Compliance Officer responsible for overseeing the implementation and enforcement of this policy, ensuring that our AML/KYC program remains effective and up to date.
2. Know Your Customer (KYC) Procedures
All users must complete identity verification before accessing the full range of CCGO services. Our KYC procedures include:
- Identity Verification: Users must provide a valid government-issued photo identification document (passport, national ID card, or driver’s license).
- Address Verification: Users must provide proof of residential address dated within the last three (3) months (utility bill, bank statement, or government correspondence).
- Selfie Verification: Users may be required to submit a live selfie or video for biometric matching against their identification documents.
- Business Verification: Merchant and agent accounts must provide business registration documents, proof of registered address, and identification of beneficial owners holding 25% or more ownership.
CCGO reserves the right to request additional documentation at any time to verify user identity and assess risk. Failure to provide requested documentation may result in account restrictions or closure.
3. Customer Due Diligence (CDD)
CCGO performs Customer Due Diligence on all users as part of the onboarding process and on an ongoing basis. CDD measures include:
- Verifying the identity of the user and, where applicable, the beneficial owner.
- Understanding the nature and purpose of the business relationship.
- Assessing the risk profile of each user based on factors such as geography, transaction volume, and business type.
- Monitoring accounts on an ongoing basis to ensure that transactions are consistent with the user’s known profile and risk assessment.
- Conducting periodic reviews of user information to ensure it remains accurate and up to date.
4. Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied to users and transactions that present a higher risk of money laundering or terrorist financing. EDD triggers include:
- Users from or operating in high-risk jurisdictions as identified by FATF or other regulatory bodies.
- Politically Exposed Persons (PEPs) and their close associates or family members.
- Complex or unusually large transactions that have no apparent economic or lawful purpose.
- Accounts with transaction patterns that deviate significantly from expected activity.
- Users involved in industries or business activities associated with higher money laundering risk.
EDD measures may include obtaining additional identification documents, verifying the source of funds, conducting enhanced background checks, and increasing the frequency of ongoing monitoring.
5. Transaction Monitoring
CCGO employs automated and manual transaction monitoring systems to detect suspicious activity. Our monitoring framework includes:
- Real-time monitoring of all transactions processed through the platform.
- Automated alerts for transactions that exceed predefined thresholds or match suspicious patterns.
- Analysis of transaction velocity, frequency, and geographic patterns.
- Detection of structuring attempts designed to avoid reporting thresholds.
- Monitoring for unusual wallet recharge or withdrawal patterns.
All flagged transactions are reviewed by our compliance team. Where necessary, accounts may be temporarily restricted pending the completion of an investigation.
6. Suspicious Activity Reporting
When CCGO identifies suspicious activity, we are obligated to file reports with the appropriate authorities. Our reporting procedures include:
- Filing Suspicious Transaction Reports (STRs) or Suspicious Activity Reports (SARs) with relevant financial intelligence units.
- Reporting within the timeframes prescribed by applicable regulations.
- Maintaining confidentiality of all reports filed, including not disclosing to the subject of the report (tipping-off prohibition).
- Cooperating fully with law enforcement investigations and regulatory inquiries.
7. Record Keeping
CCGO maintains comprehensive records in accordance with regulatory requirements, including:
- Copies of all KYC documentation and verification records for a minimum of five (5) years after the end of the business relationship.
- Transaction records, including amounts, dates, parties involved, and nature of transactions, for a minimum of seven (7) years.
- Records of all suspicious activity reports and internal investigation findings.
- Correspondence and communications related to compliance matters.
8. Sanctions Screening
All users are screened against applicable sanctions lists during onboarding and on an ongoing basis, including:
- United Nations Security Council Consolidated Sanctions List.
- U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List.
- European Union Consolidated Sanctions List.
- UK HM Treasury Financial Sanctions List.
- Other applicable national and international sanctions lists.
Any positive match will result in immediate account suspension and a thorough investigation. If the match is confirmed, the account will be permanently closed and reported to the relevant authorities.
9. Staff Training
CCGO provides regular AML/KYC training to all relevant staff, including:
- Initial AML/KYC training as part of employee onboarding.
- Annual refresher courses covering regulatory updates and emerging threats.
- Specialized training for compliance team members on investigation and reporting procedures.
- Awareness training on recognizing red flags and indicators of suspicious activity.
10. Policy Review
This AML/KYC Policy is reviewed and updated at least annually, or more frequently as required by changes in applicable laws, regulations, or business practices. The Compliance Officer is responsible for ensuring that the policy remains effective and aligned with regulatory expectations. Any material changes to this policy will be communicated to all relevant personnel.
Contact
For questions regarding our AML/KYC procedures or to report suspicious activity, please contact our compliance team at:
- Email: support@ccgo.ai
- Website: ccgo.ai