YellowCard AML/CFT/CPF Policy
YellowCard is built on a simple principle: Clean money moves faster. To protect our platform, our partners, and the people we serve, every business that works with us must understand and operate within our Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), and Counter-Proliferation Financing (CPF) policy.
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Quick Glossary AML: Anti-Money Laundering. CFT: Counter-Terrorist Financing. CPF: Counter-Proliferation Financing. KYB: Know Your Business. EDD: Enhanced Due Diligence. PEP: Politically Exposed Person. UBO: Ultimate Beneficial Owner. |
Our Core commitment
YellowCard will not participate in, facilitate, or ignore money laundering, terrorist financing, proliferation financing, or any other illegal activity. This applies to every employee, every partner, and every transaction on our platform.
Any employee found to have aided or facilitated illegal activity, whether knowingly or through negligence, faces disciplinary action, including suspension, dismissal, or personal civil penalties.
We review and update our AML policies regularly to stay aligned with changes in law, international standards, and industry best practices.
Your Responsibility as a Partner
Compliance is shared. You are responsible for properly identifying the customers you onboard through our platform and ensuring the transactions you process are legitimate. YellowCard is a partner in compliance, not a substitute for it.
What We Absolutely Prohibit
The following are hard limits. No escalation, exception, or workaround will change the outcome.
| Prohibition | What It Means |
| Anonymous customers | Every customer must be identified before any transaction. We will not open and will close any account where identity cannot be verified. |
| Predicate offenses | We do not work with individuals or entities linked to organised crime, trafficking, fraud, corruption, cybercrime, terrorism, or any other predicate offence. |
| Sanctioned entities and countries | No transactions with sanctioned countries, individuals, entities, or wallet addresses. See the Global Sanctions Policy for the full list. |
| Shell banks and shell companies | Zero tolerance. All ownership must be registered and fully transparent. Entities with no legitimate business purpose, physical presence, or verifiable ownership will be refused. |
| Cash transactions | YellowCard does not accept or process cash. All transactions go through licensed payment processors and banks. |
| Cross-border electronic fund transfers | YellowCard is not authorised to conduct cross-border EFTs across any of its global operations. |
| Unscreened non-custodial wallets | Every unhosted wallet address is screened through a blockchain analytics tool before a transaction completes. High-risk results will stop the transaction. |
| Bearer shares | Zero tolerance. All shares must be registered. Any entity issuing or holding bearer shares will be refused unless those shares are immobilised or converted to registered shares. |
Prohibited Business Industries
The following business types will not be onboarded.
| Industry | Why It Is Prohibited |
| DeFi protocols | No AML controls. High exposure to exploits and illicit activity. |
| Crypto mixers and privacy coin providers | Designed to break the link between sender and recipient. The primary tool for laundering funds. |
| NFT and digital asset marketplaces | High-volume pseudonymous transactions involving high-value assets are a known vehicle for laundering funds. |
| Terrorist financing and sanctioned entities | Globally prohibited under UN, OFAC, and FATF rules. Severe legal penalties apply. |
| Trafficking (drugs, humans, arms, goods) | Universally illegal predicate offences for money laundering. |
| Fraudulent schemes (Ponzi, pyramid, shell entities) | Designed to defraud, scam, or evade tax obligations. |
| Anonymous financial services | Any service designed to hide the origin of funds violates core AML standards. |
| Child Sexual Abuse Material (CSAM) | A fundamental violation of human rights. Not a policy matter — a moral and legal absolute. |
| Offensive weapons and explosives | Production or distribution of firearms, military-grade weapons, or dual-use goods. |
| Intellectual property theft | Sale or distribution of counterfeit or stolen goods. |
Some industries are legal but carry elevated risk. YellowCard will only engage with the following if they are properly licensed and meet our compliance requirements:
| Industry | Condition for Engagement |
| Gambling | Must hold a valid license in its operating jurisdiction. |
| Unlicensed money services (MSBs) | Valid license required where a licensing regime exists. |
| Multi-level marketing | Full KYC, EDD, and Senior Management approval required. |
| Cannabis and marijuana | Case-by-case review. EDD and Senior Management approval required. |
| Adult entertainment | Full EDD, ongoing monitoring, and Senior Management approval required. |
Restricted Industries and Relationships
These industries are not prohibited but require a higher level of scrutiny. Senior Management approval, EDD, and documented risk mitigations are mandatory for every relationship in this category. All are subject to ongoing monitoring.
| Industry or Relationship | Key Requirement |
| Politically Exposed Persons (PEPs) | Senior Management approval. EDD. Source of wealth and funds verified. Classified as high risk throughout the relationship. |
| Government-owned and government-linked entities | Classified as a severe risk. EDD, Senior Management approval, and documented mitigations are mandatory. |
| Licensed gambling institutions | Valid license required. EDD. Senior Management approval. |
| Used car dealers | EDD and source of funds documentation required. Senior Management sign-off needed. |
| Regulated charities | EDD. Verified beneficiary structures. Senior Management approval. |
| Extractive industries (mining, precious metals, etc.) | EDD. Supply chain due diligence. Senior Management approval. |
| Unlicensed or unregulated exchanges and trading platforms | Must demonstrate compliance measures. EDD is mandatory regardless of licensing status. |
| Unlicensed crypto services | Evidence of AML and FATF Travel Rule compliance is required. EDD. Senior Management approval. |
How We Assess Risk
YellowCard uses a risk-based approach to every business relationship. The level of due diligence applied matches the level of risk each customer represents.
| Risk Level | Who This Applies To | What We Do |
| Low | Standard businesses with transparent ownership and no adverse history. | Standard CDD. Routine ongoing monitoring. |
| Medium | Some complexity, moderate-risk industry, or limited information gaps. | Standard to enhanced CDD with appropriate controls in place. |
| High | PEPs, complex ownership structures, high-risk industries, or adverse media. | EDD mandatory. Senior Management approval. Enhanced ongoing monitoring. |
| Severe | Government-owned entities or businesses approaching prohibited categories. | Only onboarded on an exceptional basis. EDD, Senior Management approval, and documented mitigations required. |
Ongoing Monitoring
All customers are monitored continuously regardless of their risk level. We track transaction behaviour, source of funds, and adherence to declared business activity. Where these cannot be maintained, YellowCard may suspend or terminate the relationship.
Eligible Virtual Assets
YellowCard only supports stablecoins of good standing. Currently: USDT and USDC. Any virtual asset linked to fraud, illicit schemes, or sanctions risk is prohibited from our platform.
What This Means for You
As a B2B partner or developer, here is what you need to do:
- Submit complete and accurate KYC metadata for every transaction that requires it. Missing data will cause transactions to fail.
- Do not knowingly onboard or serve customers who fall into any prohibited category.
- Disclose the full ownership structure of your business during onboarding, including any UBOs who are PEPs.
- If you suspect a customer is involved in illicit activity, do not process the transaction. Contact YellowCard immediately.
- If your business operates in a restricted or higher-risk industry, disclose this upfront. We will determine the appropriate due diligence together.
- Your end customers are subject to YellowCard's KYT (Know Your Transaction) monitoring. Flagged transactions will be held or rejected automatically.
PEP and UBO Disclosure:
If any UBO of your business holds or has held a position of public function, making them a PEP, you must disclose this during onboarding. Failure to do so is a compliance violation and may result in termination of the relationship.