AML/KYC Policy

1. Introduction and Commitment

Novi P2P ("Novi", "we", "us", or "our") is committed to operating a safe, compliant, and transparent peer-to-peer cryptocurrency trading platform. This Anti-Money Laundering and Know Your Customer Policy ("AML/KYC Policy") outlines the measures we take to prevent the Platform from being used for money laundering, terrorist financing, sanctions evasion, or any other illegal financial activity.

Novi maintains a risk-based compliance program designed to detect and deter financial crime while preserving the privacy and autonomy of legitimate users. All users of the Platform are subject to this policy.

2. Regulatory Framework

Our AML/KYC program is informed by internationally recognized standards and applicable legal frameworks, including:

• Financial Action Task Force (FATF) Recommendations on virtual assets and virtual asset service providers
• The U.S. Bank Secrecy Act (BSA) and implementing regulations
• EU Anti-Money Laundering Directives (AMLD5/AMLD6)
• Office of Foreign Assets Control (OFAC) sanctions programs
• Applicable national and local financial crime prevention laws in jurisdictions we serve

We continuously monitor developments in regulatory guidance for cryptocurrency and virtual asset platforms and update our program accordingly.

3. Customer Identification

3.1 Account Registration: All users must provide accurate identifying information at registration, including a valid name and email address. By creating an account, you confirm that the identity information you provide is truthful and your own.

3.2 Identity Verification: Novi currently operates a registration-based identity model without mandatory document-based KYC for standard trading. However, we reserve the right to request additional identity verification at any time, including:

• Government-issued photo identification (passport, national ID, driver's license)
• Proof of address (utility bill, bank statement dated within 90 days)
• Selfie or liveness check for identity confirmation
• Source of funds declaration for high-value transactions

3.3 Refusal of Service: We reserve the right to refuse, restrict, or terminate service to any user who fails to provide requested identity verification, provides false or misleading information, or whose activity raises AML/compliance concerns.

4. Risk-Based Approach

Novi applies a risk-based approach to AML compliance. User accounts and transactions are assessed across multiple risk dimensions:

Accounts assessed as medium or high risk may be subject to enhanced due diligence, trading restrictions, account freezes, or termination.

5. Transaction Monitoring

Novi employs automated and manual transaction monitoring systems to detect potentially suspicious activity. Monitored behaviors include:

• Rapid, high-volume trading inconsistent with user history
• Transactions involving wallet addresses linked to known illicit activity
• Patterns consistent with layering, smurfing, or structuring
• Repeated disputes, chargebacks, or payment reversals
• Trades designed to convert funds across multiple cryptocurrencies without economic rationale
• Unusual geographic patterns or login anomalies coinciding with large trades

Where AI-assisted fraud detection is employed, it serves as a supplementary tool. All high-risk flags are subject to human review before enforcement action is taken.

6. Suspicious Activity and Reporting

When suspicious activity is identified, Novi will:

• Place a temporary hold on affected accounts and transactions pending investigation
• Conduct an internal review of available evidence, trade history, and user communications
• File a Suspicious Activity Report (SAR) or equivalent with the appropriate financial intelligence unit where legally required
• Cooperate fully with law enforcement and regulatory inquiries

Tipping Off Prohibition: In accordance with applicable law, we are prohibited from alerting a user that a SAR has been filed concerning their activity. Account restrictions related to an active investigation may be applied without explanation.

7. Record Keeping

We maintain records in compliance with applicable AML regulations:

• Transaction Records: Full records of all trades, including counterparties, amounts, timestamps, and cryptocurrency transaction hashes — retained for a minimum of 7 years
• Identity Records: Account registration data, verification documents, and KYC records — retained for 7 years following account closure
• Communication Records: Trade chat logs used in compliance investigations — retained for 2 years after trade completion
• SAR and Investigation Files: Retained for a minimum of 5 years from the date of filing

Records are stored securely with access restricted to authorized compliance personnel and, where legally required, government authorities.

8. Sanctions Screening and Prohibited Jurisdictions

8.1 Sanctions Screening: All user accounts are screened against international sanctions lists at registration and on an ongoing basis, including:

• U.S. OFAC Specially Designated Nationals (SDN) List
• EU Consolidated Sanctions List
• United Nations Security Council Consolidated List
• UK HM Treasury Financial Sanctions List

8.2 Prohibited Jurisdictions: Access to and use of the Platform is strictly prohibited for users located in, citizens of, or acting on behalf of entities in the following jurisdictions (this list is not exhaustive and may be updated):

• Iran
• North Korea (Democratic People's Republic of Korea)
• Cuba
• Syria
• Crimea, Donetsk, and Luhansk regions of Ukraine (under current sanctions)
• Any other jurisdiction subject to comprehensive international financial sanctions

Accounts detected as operating from or in violation of these restrictions will be immediately suspended and funds frozen pending compliance review.

9. Voluntary Enhanced Verification

Users may voluntarily complete enhanced KYC verification to unlock higher trading limits and gain additional trust signals on their profile. Verified users may benefit from:

• A verified badge displayed on their public profile
• Eligibility for higher single-trade volume limits
• Expedited dispute resolution in their favor when identity is verified
• Increased counterparty trust and trade acceptance rates

Voluntary verification requires submission of government-issued ID and proof of address. Submitted documents are handled in accordance with our Privacy Policy and deleted after verification is complete, unless retention is legally required.

10. User Obligations

By using the Platform, you agree to:

• Only trade with funds you legally own and that represent legitimate sources of wealth
• Not use the Platform to conceal, transfer, or launder proceeds of any criminal activity
• Promptly respond to any identity verification or source-of-funds request from Novi's compliance team
• Not attempt to circumvent our AML controls, including through the use of VPNs, proxies, or false identity information to access the Platform from prohibited jurisdictions
• Report any suspicious behavior by other users to support@novip2p.com

Violation of these obligations constitutes a material breach of our Terms of Service and may result in immediate account termination and referral to law enforcement.

11. Changes to This Policy

We review and update this AML/KYC Policy regularly to reflect changes in regulatory requirements, industry standards, and Platform operations. Material changes will be announced via email and Platform notice. Continued use of the Platform following any update constitutes your acceptance of the revised policy. The "Last updated" date at the top of this page reflects the most recent revision.

12. Contact Us

For questions about this AML/KYC Policy, compliance matters, or to report suspicious activity: