Anti-Money-Laundering (AML) Policy

This anti-money-laundering policy is set and enforced by AGGS TECHNOLOGY SERVICES CO., LIMITED ("the Company"), which is incorporated in the Hong Kong Special Administrative Region.

The virtual credit card brand the Company operates, "RDVCC" ("the Platform"), works with its upstream licensed card issuer to observe international anti-money-laundering (AML) and counter-terrorist-financing (CFT) rules. We treat "detect early, block early, report early" as an operating floor rather than waiting for a regulator to act.

Before opening a card, every user must complete cardholder verification (name + 11-digit mainland-China mobile number) and pass our risk-control rules and anti-abuse defences.

The Platform runs the following monitoring:

• Large-amount alerts: a single top up or card operation — or a daily total — above a preset threshold triggers manual review;
• High-frequency small-amount alerts: multiple small operations that look like structuring;
• Address blacklists: a USDT top-up address that matches an on-chain blacklist (OFAC sanctions, stolen funds, mixer output) is frozen immediately;
• MCC anomalies: card transaction categories inconsistent with the user's behaviour profile trigger review;
• IP / device risk control: many accounts on one device, unusual logins from new locations, IP hopping.

RDVCC strictly prohibits the following; offending accounts are frozen immediately:

• money laundering, assisting money laundering, or providing tools for it;
• terrorist financing;
• proceeds of fraud, pyramid schemes or illegal fundraising;
• funds connected to drugs, weapons or human trafficking;
• payments for gambling, pornography or prohibited goods;
• cashing out / withdrawing to a domestic bank card;
• commercial payment-on-behalf or grey-market payment processing;
• impersonation or false cardholder details.

If we receive a lawful investigation request from the public security, procuratorial, judicial, foreign-exchange or other authorised agencies of the People's Republic of China (for example an assistance-with-investigation notice or a notice to assist in a funds freeze), RDVCC will cooperate as the law requires and provide the necessary account and transaction records.

For accounts involved in criminal activity, we will report proactively to the competent authority as required by law.

• compliance training before staff start, refreshed annually;
• sensitive operations pass through the admin audit log, which cannot be altered;
• an independent reporting line for the compliance officer.

RDVCC keeps every account under continuous risk rating, adjusting the rating dynamically on the following signals:

• account age (new accounts start at a higher rating, lowered automatically after 6 months);
• top-up frequency and amounts (unusually frequent or unusually large raises the rating);
• spending pattern (concentration in one high-risk merchant category draws attention);
• geographic jumps (IP / device hopping across several countries in a short time);
• compliance history (past reports, appeals or warnings).

High-risk accounts are added automatically to an "enhanced due diligence" queue, where new transactions are reviewed one by one. Ordinary users never notice any of this.

RDVCC accepts the compliance requirements of international anti-money-laundering bodies (FATF), the AML centre of the People's Bank of China, the Hong Kong Monetary Authority and comparable regulators. On receiving a lawful assistance or evidence request, RDVCC will:

• verify the requester's identity and the lawfulness of the request;
• provide only the minimum necessary data within the scope requested;
• write an audit-log entry for every disclosure (retained for 7 years);
• notify the account holder under investigation where the law permits (criminal cases excepted).

All RDVCC staff (support, operations and engineering included) receive at least 8 hours of anti-money-laundering and counter-terrorist-financing training each year. It covers:

• the AML legal framework (China's Anti-Money Laundering Law, Hong Kong's Anti-Money Laundering and Counter-Terrorist Financing Ordinance, FATF standards and similar);
• customer identification (KYC) rules and good practice;
• concrete scenarios and red flags for suspicious transactions;
• when enhanced due diligence (EDD) applies;
• reporting and escalation procedures;
• internal sanctions for compliance breaches.

New staff must finish onboarding training within 30 days and pass the test before they can touch user data. Training records and test results are kept in their personnel file.

If you believe an RDVCC user may be laundering money or otherwise breaking these rules, please contact [email protected]. We keep the reporter's identity confidential.