Risk-based AML/CFT controls.

Governance and accountable officer

Compliance Officer / MLRO, LETTVEI oversees program implementation, escalation, training, reporting, and remediation. Contact: support@lettvei.com · +52 984 133 1219.

Risk-based approach

Customer, geography, product, asset, channel, counterparty, velocity, and behavioral risks are assessed at onboarding and throughout the relationship. Controls and review frequency increase with risk.

EDD triggers

• First XMR deposit and XMR activity above program thresholds.
• Any crypto deposit above $1,000 requiring source-of-funds or source-of-wealth support.
• PEP exposure, high-risk geography, adverse media, sanctions proximity, unusual velocity, third-party funding, or activity inconsistent with the profile.

Monitoring and reporting

Identity, deposits, conversion, fiat card activity, sanctions, PEP, fraud, and behavioral indicators are monitored. LETTVEI commits to timely notices under Mexico’s LFPIORPI framework and SAR/ROS filing or partner escalation under applicable partner-jurisdiction rules. No customer is tipped off.

Records, audit, and training

Required customer, due-diligence, transaction, alert, investigation, and reporting records are retained for ten years where current Mexican requirements apply, or longer where another binding rule requires. The program is subject to annual independent audit and documented remediation; role-based training occurs at onboarding and at least annually.