CitadelVest Pro maintains a zero-tolerance policy toward money laundering, terrorist financing, and all other forms of financial crime. This policy outlines the measures we take to prevent the Platform from being used for illegal financial activity and the obligations of all users who access our services.
1. Policy Overview
CitadelVest Pro ("Platform," "we," or "our") is committed to complying with all applicable anti-money laundering (AML) and counter-terrorism financing (CTF) laws and regulations. This policy applies to all users of the Platform, all transactions processed through the Platform, and all staff involved in Platform operations.
The goal of this policy is to ensure the Platform is not used, intentionally or otherwise, to facilitate money laundering, terrorist financing, tax evasion, sanctions violations, or any other financial crime.
This policy is reviewed and updated regularly to reflect changes in applicable law and regulatory guidance.
2. Key Definitions
- Money Laundering: The process of making illegally obtained funds appear legitimate by passing them through a series of transactions or a legitimate business.
- Terrorist Financing: The provision of financial support for acts of terrorism or organizations that engage in terrorism.
- KYC (Know Your Customer): The process of verifying the identity of users through collection and review of identity documents and other information.
- CDD (Customer Due Diligence): Ongoing assessment of user risk, including understanding the nature and purpose of the user's account and transactions.
- EDD (Enhanced Due Diligence): Additional verification measures applied to users or transactions that present higher risk factors.
- PEP (Politically Exposed Person): An individual who holds or has recently held a prominent public function, who may present higher risk of involvement in bribery or corruption.
- STR (Suspicious Transaction Report): A report filed with relevant authorities when a transaction is suspected of involving criminal funds.
3. KYC Requirements
All users are subject to Know Your Customer verification. The level of verification required depends on the user's activity level and risk profile:
Basic Verification (all users):
- Valid email address (verified)
- Phone number (OTP-verified)
- Full name
Full KYC (required for higher withdrawal thresholds or flagged accounts):
- Government-issued photo ID (passport, national identity card, or driver's license)
- Proof of address (utility bill or bank statement dated within 3 months)
- Selfie or live photo for facial comparison
Enhanced Due Diligence (EDD) — triggered when:
- Transaction volumes exceed defined thresholds
- The user is identified as a Politically Exposed Person (PEP)
- The user's country presents elevated risk per international AML standards (FATF)
- Unusual or inconsistent transaction patterns are detected
- The user's source of funds is unclear or unverifiable
EDD may include requests for source of funds documentation, proof of income, or a video verification call. Failure to provide required documentation within a reasonable timeframe may result in account restrictions or closure.
4. Prohibited Persons & Entities
The following persons and entities are strictly prohibited from using the Platform:
- Individuals or entities listed on any government or international sanctions list, including OFAC (US), UN Security Council, EU, HM Treasury (UK), or other relevant authorities
- Individuals or entities that are the subject of any government investigation for financial crime, fraud, or terrorism
- Persons acting on behalf of a sanctioned individual or entity
- Shell companies or entities with opaque ownership structures designed to obscure beneficial ownership
- Persons located in or ordinarily resident in FATF high-risk or blacklisted jurisdictions
By registering and using the Platform, you represent and warrant that you do not fall within any of the prohibited categories above.
5. Transaction Monitoring
The Platform employs automated and manual transaction monitoring to identify patterns or transactions that may indicate financial crime. Monitoring includes:
- Review of all deposits and withdrawals for unusual amounts or frequencies
- Comparison of transaction patterns against the user's established account history and stated purpose
- Automatic flagging of transactions that meet defined risk criteria (rapid deposit-to-withdrawal patterns, unusually large amounts relative to account age, structuring patterns)
- Verification of withdrawal addresses against known blacklisted blockchain addresses
- Periodic review of high-risk accounts
Users whose accounts are flagged for monitoring review may experience delays in transaction processing while the review is conducted. We are not required to notify users that they are under enhanced monitoring.
6. Red Flags & Suspicious Activity Indicators
🚩 The following behaviors are treated as potential red flags requiring investigation:
- Withdrawal request submitted within 30 minutes of a deposit, particularly for large amounts
- Withdrawal amount representing more than 80% of total lifetime deposits within a short period
- Three or more withdrawal requests within a 24-hour period
- New account (less than 7 days old) attempting a large withdrawal
- Multiple failed KYC submissions or submission of inconsistent identity documents
- User providing multiple different wallet addresses in a short period
- Account registered with disposable or temporary email addresses
- Login from an unusually high number of different countries in a short time period
- Deposits received from blockchain addresses flagged by chain analytics as associated with illicit activity
- Repeated account creation attempts after previous account closure or suspension
The presence of one or more red flags does not necessarily mean that illegal activity has occurred. However, flagged accounts are subject to additional review and may require the user to provide supporting documentation before transactions are processed.
7. Reporting Obligations
The Platform is committed to cooperating fully with relevant law enforcement and financial intelligence authorities. Where we identify transactions or account activity that we reasonably suspect involves money laundering, terrorist financing, or other financial crime, we are obligated to:
- File a Suspicious Transaction Report (STR) or Suspicious Activity Report (SAR) with the relevant financial intelligence unit or authority
- Freeze or restrict the relevant account and associated funds pending investigation
- Cooperate fully with any law enforcement investigation or court order
- Retain all relevant records for the duration of any investigation and as required by law
⚠️ Tipping Off: Under applicable AML laws, we are legally prohibited from informing ("tipping off") a user or third party that they are the subject of a suspicious activity report or ongoing investigation. If your account is frozen or restricted and we are unable to provide a reason, this may be the cause.
8. Sanctions Screening
All users are screened against applicable sanctions lists at the time of registration and on an ongoing basis. This includes screening against:
- OFAC Specially Designated Nationals (SDN) List
- United Nations Security Council Consolidated List
- European Union Consolidated Financial Sanctions List
- HM Treasury UK Financial Sanctions List
- Other relevant national and international sanctions lists
Any account found to be associated with a sanctioned individual or entity will be immediately frozen and reported to the appropriate authority. Funds associated with sanctioned accounts may be subject to permanent freezing under applicable law.
9. Record Keeping
In accordance with applicable AML regulations, the Platform retains the following records for a minimum of 5 years from the date of the transaction or account closure, whichever is later:
- All user identity documents and KYC verification records
- Complete transaction history (deposits, withdrawals, investments)
- All correspondence related to account activity, including support chats and emails
- Risk assessments and due diligence records
- Any suspicious activity reports filed
These records are maintained securely and are available to regulatory and law enforcement authorities upon lawful request.
10. User Obligations
By using the Platform, you agree to the following obligations:
- You will only deposit and invest funds that are of legitimate origin
- You will provide accurate and truthful information at registration and at any subsequent point when information is requested
- You will promptly provide any documentation requested by the Platform for KYC or EDD purposes
- You will not attempt to use the Platform to structure transactions in a way designed to avoid reporting thresholds or monitoring
- You will immediately notify the Platform if you become aware that your account has been used without your authorization or for illegal purposes
- You understand that we are legally obligated to report suspected financial crime and that doing so does not constitute a breach of any contractual obligation to you
11. Enforcement & Consequences
Violations of this AML Policy — or any use of the Platform for money laundering, terrorist financing, fraud, or other financial crime — will result in:
- Immediate suspension or permanent termination of the user's account
- Freezing of all funds in the account pending investigation
- Reporting to relevant financial intelligence units, law enforcement agencies, and regulatory bodies
- Cooperation with any subsequent law enforcement investigation or legal proceedings
- Forfeiture of any funds determined to be of illicit origin
The Platform reserves the right to share user data with authorities without notice when required by law or when we believe doing so is necessary to protect the integrity of the financial system.