AML/CFT Policy

1. Introduction

Cloakd is a Netherlands-registered non-custodial cryptocurrency payment infrastructure provider. Cloakd enables merchants to accept crypto payments from their customers.

Cloakd is committed to preventing its services from being used for money laundering, terrorist financing, or any other financial crime. This policy describes the measures Cloakd takes to meet those obligations under applicable Dutch and EU law, including the Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft) and the Sanctiewet 1977.

2. Scope

This policy applies to:

• Merchants — businesses and individuals who apply to use Cloakd's payment infrastructure (Cloakd's B2B clients)
• Cloakd's personnel and any representatives or partners

This policy does not impose identity verification on end-customers making payments through a merchant's checkout. End-customers are not Cloakd's clients and are not subject to customer due diligence under this policy. This is consistent with how all regulated payment processors operate: Stripe verifies businesses, not individual cardholders.

3. Merchant Onboarding (Know Your Business)

Before activating any merchant account, Cloakd collects and reviews the following information:

• Legal business name and entity type
• Country of registration
• Name of owner(s) / director(s)
• Business website URL
• Business type and vertical / industry
• Estimated monthly transaction volume
• Settlement wallet address

This information is reviewed before account activation. For higher-volume merchants or merchants in elevated-risk verticals, Cloakd may request additional documentation. Cloakd reserves the right to decline or terminate any merchant relationship, including where information provided cannot be verified or appears inconsistent.

4. Prohibited Use Cases

Cloakd's services may not be used, directly or indirectly, in connection with:

• Illegal goods, services, or activities of any kind under applicable law
• Child sexual abuse material (CSAM) or any exploitation of minors
• Illegal weapons, ammunition, explosives, or weapons of mass destruction
• Human trafficking, forced labour, or sexual exploitation
• Terrorism financing, or any support for sanctioned persons, entities, or regimes
• Dark web marketplaces or platforms designed to facilitate anonymous illegal activity
• Fraud, scams, or deceptive schemes of any kind
• Money laundering or deliberate layering of illicit funds

Merchants found to be engaged in prohibited activities will have their accounts suspended immediately and permanently. Cloakd reserves the right to report such activity to FIU-Nederland and other relevant authorities.

5. Sanctions Compliance

Cloakd complies with EU sanctions regulations and the Dutch Sanctiewet 1977. Cloakd does not provide services to:

• Persons or entities on EU, UN, or OFAC sanctions lists
• Merchants operating from or primarily serving sanctioned jurisdictions

Cloakd periodically screens merchant information against applicable sanctions lists.

6. Transaction Monitoring

Cloakd monitors transaction activity for indicators of suspicious or unusual behaviour, including:

• Sudden unexplained increases in transaction volume
• Transaction patterns inconsistent with a merchant's stated business type
• Repeated activity involving high-risk or sanctioned jurisdictions

Where suspicious activity is identified, Cloakd will investigate. Where required by law, Cloakd will file a suspicious activity report (Melding Ongebruikelijke Transactie) with FIU-Nederland.

7. Record Keeping

Cloakd retains merchant onboarding records and transaction logs for a minimum of 5 years following the end of the merchant relationship, in accordance with Wwft requirements.

8. Risk-Based Approach

Cloakd applies a risk-based approach to AML/CFT compliance, consistent with DNB and AFM guidance. At current operating scale, with a small number of vetted B2B merchants, proportionate measures are applied. As Cloakd scales, this policy will be reviewed and updated accordingly.

9. Contact

For questions about this policy, or to report suspected misuse of Cloakd's platform:

Email: info@cloakd.ai