1. Purpose and scope
This policy summarises the anti-money-laundering (“AML”), counter-terrorist-financing (“CTF”) and know-your-customer (“KYC”) program operated by Aristotle Intelligence Inc., a Delaware C Corporation (Delaware File Number 10557887), which offers its platform under the brand Cardeo. It applies to the Cardeo platform, website, and applications, and to everyone who applies for or uses the services made available through them.
This is a public summary. It does not reproduce our internal procedures, thresholds, or monitoring rules, and it does not form part of any contract. The binding terms are in our Terms of Use.
2. Our role, and what we are not
Cardeo is a technology platform and program enabler. Aristotle Intelligence Inc. is not a bank, an electronic money institution, a payment institution, a money services business, a stored-value facility, or a virtual asset service provider, and it does not hold a financial-services licence. It does not hold, store, safeguard, control, or manage customer funds, and it does not issue e-money or execute payment transactions.
All regulated financial services — including safeguarding of funds, issuance of e-money and cards, and execution of payments — are provided by licensed Underlying Financial Institution(s). Those institutions are identified in the Regulatory Disclosure Annex to our Terms of Use, and each of them operates under its own licence and its own regulatory supervision. Where this policy describes a control that is performed by a regulated institution rather than by us, that is stated.
Because the regulated activity sits with those institutions, statutory AML obligations such as the filing of suspicious activity reports with a competent authority are discharged by the relevant regulated institution, and not by us.
3. Governance
- We maintain a written AML/CTF and sanctions program, and we assign senior-level responsibility for it.
- We apply a risk-based approach: the checks applied to a customer or a transaction are proportionate to the risk it presents.
- Personnel in relevant roles receive AML/CTF, sanctions, and fraud-awareness training appropriate to their duties.
- We review the program periodically, and after material changes to our services, our partners, or applicable law.
- We are contractually required to meet the AML, CTF, sanctions, and onboarding standards imposed by our Underlying Financial Institution(s), and we are subject to their oversight and audit rights.
4. Customer due diligence (KYC)
Access to financial services through the Cardeo platform requires identification and verification. Depending on the product and the risk presented, due diligence may include:
- verification of identity, including name, date of birth, nationality, and residential address;
- collection and validation of government-issued identity documents, and biometric or liveness checks, including a facial image;
- proof of address, and information on source of funds or source of wealth;
- for business customers, verification of the legal entity, its ownership and control structure, and its beneficial owners;
- screening for politically exposed person (“PEP”) status and adverse media.
The regulated customer due diligence obligation sits with the Underlying Financial Institution(s), not with us. We collect and verify this information for that purpose, in support of and to the standards set by those institutions, using specialist identity-verification providers; the providers with whom we share personal data for this purpose are identified in our Privacy Policy. The Underlying Financial Institution(s) may apply their own additional checks and conditions, they make the final acceptance decision, and acceptance by them is a precondition of access to the regulated services.
Enhanced due diligence is applied to higher-risk relationships. Where we or a partner cannot complete due diligence to our satisfaction, the application will be refused, or an existing relationship suspended or terminated. We do not accept anonymous or pseudonymous customers, and we do not permit an account to be used by, or on behalf of, anyone other than the verified customer.
Customer information is kept under review, and we may ask for updated documents or information during the relationship.
5. Sanctions and restricted activity
Customers and transactions are screened against the sanctions and watch lists applicable to us and to our Underlying Financial Institution(s). We do not establish or maintain relationships with sanctioned persons or entities, and services are not available in jurisdictions restricted by us, by our partners, or by applicable law.
The platform must not be used for money laundering, terrorist financing, sanctions evasion, fraud, or any other unlawful purpose. Prohibited and restricted uses are set out in our Terms of Use.
6. Monitoring and escalation
Activity on the platform is monitored on a risk-based basis by us and by the Underlying Financial Institution(s), using automated and manual controls, in order to identify activity that is unusual or inconsistent with what we know about a customer. Where activity warrants it, we may request further information, apply limits within the platform, decline to transmit an instruction, or suspend access to the platform, and we escalate the matter to the relevant regulated institution so that it can discharge its own reporting obligations. Blocking, reversing, freezing or retaining funds is done by the Underlying Financial Institution(s), not by us.
Where the law prohibits it, we will not tip off a customer that their activity has been reported or is under investigation.
7. Record keeping
Identification records, due diligence records, and transaction records are retained for the periods required by applicable law and by the Underlying Financial Institution(s) whose programs we support — typically for at least five years after the end of a customer relationship — and for longer where a specific legal, regulatory, or audit requirement applies. Retention is described further in our Privacy Policy.
8. Cooperation with authorities
We cooperate with our Underlying Financial Institution(s), and with competent authorities and law-enforcement agencies acting within their powers, including in responding to lawful requests for information.
9. Contact
Questions about this policy, or about a due diligence request you have received, can be sent to info@cardeo.pro, or by post to Aristotle Intelligence Inc., 1111B South Governors Avenue, Suite 28, Dover, DE 19904, United States.