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AML

Effective from: 03.04.2026

Last Updated: 03.04.2026


1. Policy Purpose & Scope

This Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) Policy establishes the regulatory, procedural, and operational framework by which Crowngreen.com ensures full compliance with the obligations of:

  • Applicable international AML standards (e.g., FATF Recommendations, EU Directives, relevant international AML/CFT standards).

  • Best practices in risk-based KYC and crypto-transaction controls.

This Policy applies to all business units, employees, customer support agents, contractors, vendors, and technology providers involved in customer acquisition, payment handling, and compliance operations.


2. Definitions and Abbreviations 

  • AML - Anti-Money Laundering.

  • CFT - Counter-Financing of Terrorism.

  • CD - Customer Due Diligence.

  • EDD - Enhanced Due Diligence.

  • KYC - Know Your Customer.

  • PEP - Politically Exposed Person.

  • SAR - Suspicious Activity Report.

  • SOF - Source of Funds.

  • SOW - Source of Wealth.

  • CTR - Currency Transaction Report.

  • FIU - Financial Intelligence Unit.

  • PSP - Payment Service Provider.


3. Regulatory Compliance Overview

3-102-956921 SOCIEDAD DE RESPONSABILIDAD LIMITADA adheres to the AML/CFT obligations as outlined by:

  • Mandatory SAR reporting within 24 hours of suspicion.

  • Threshold-based CDD (EUR 10,000+).

  • Monitoring for structured transactions.

  • Self-exclusion reporting.

Additionally, the Company aligns with the expectations of the EU AMLD5/6 framework to enable jurisdictional scalability and maintain PSP relationships.


4. Risk-Based Approach (RBA)

The Company maintains a documented Risk-Based Approach to allocate AML efforts proportionate to the customer, transactional, geographic, and product risk.

  4.1 Customer Risk Categories

  • Low Risk: Verified users from regulated jurisdictions with normal transactional patterns.

  • Medium Risk: Higher-volume users or residents of countries with moderate AML risk.

  • High Risk: Crypto-only users, PEPs, users from high-risk jurisdictions (per FATF).

  4.2 Product & Payment Risk

  • PSPs assessed based on licensing, settlement flow, reversibility, and fraud history.

  • Crypto assets (BTC, ETH, USDT, LTC, TRX) subject to chain analysis screening.

  4.3 Geographic Risk

  • Access restricted for users from prohibited or locally regulated jurisdictions (e.g., jurisdictions subject to gaming restrictions or enhanced AML expectations).

  • Geo-blocking tools and IP/time-zone validation used to enforce territorial restrictions.


5. Customer Due Diligence (CDD) Procedures

The Company applies a risk-based approach to Customer Due Diligence (CDD), with verification requirements escalating based on transaction volume, payment method, and behavioral risk indicators. Thresholds and verification levels are defined internally and subject to continuous review.

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