Examiner brief · XMR

Why full-KYC Monero works.

Monero is treated as a higher-risk funding asset inside a known-customer, immediate-conversion, fiat-only card architecture.

01 · Identity before acceptance

Every XMR deposit is tied to an approved, verified customer before a deposit address is enabled. No anonymous funds are accepted into the program. EDD is completed before the customer’s first XMR deposit.

02 · No XMR card balance

Accepted XMR is converted to fiat on arrival through a banking and card partners are disclosed during onboarding where applicable. LETTVEI does not hold an XMR card balance, transmit XMR over card rails, or make XMR spendable. The proposed card is fiat-only.

03 · Compensating controls

  • Source-of-funds and, where warranted, source-of-wealth evidence for XMR deposits above $1,000.
  • Per-tier XMR monthly caps of $1,000, $5,000, and $10,000, lower than general load limits.
  • Deposit velocity, structuring, linked-account, device, geography, counterparty, conversion, and fiat-spend behavior rules.
  • Manual Compliance review for alerts and for material deviation from expected activity.

Verification and monitoring providers are disclosed where required during due diligence.

04 · Travel Rule

Required originator and beneficiary information is collected and exchanged through off-chain messaging or partner procedures where applicable. An XMR transfer is held, rejected, or returned where legally required information cannot be established or transmitted. Self-hosted wallet use receives ownership and counterparty review proportionate to risk.

05 · SAR / ROS commitment

LETTVEI investigates and files or escalates a SAR/ROS or Mexican notice when the facts and applicable rules require. Example triggers include unexplained third-party funding, rapid repeated deposits below thresholds, inconsistent wealth evidence, sanctions or darknet exposure indicators, mule-account behavior, rapid fiat cash-out, linked-account patterns, false documents, or refusal to provide required Travel Rule information. Filing decisions are confidential and documented.