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.

Every user must complete identity verification (valid ID + liveness face check) before a card is opened; the check also screens against sanctions, politically exposed person and adverse lists, and one ID document can be linked to only one account.

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;
• Funding-address screening: top ups are screened on-chain by our licensed payment processor for risky addresses (sanctions, stolen funds, mixer output); matches are blocked by the processor;
• Merchant and category blocking: high-risk merchants and categories are blocked under each card's usage policy and our merchant blacklist; a hit freezes the card;
• Linked-account detection: a second account on the same ID document is rejected, and an ID that matches a banned account is banned too; payouts are restricted for 48 hours after account credentials change.

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 bank card;
• commercial payment-on-behalf or grey-market payment processing;
• Identity fraud, using someone else's document or false identity data.

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:

• identity verification and screening results;
• top-up frequency and amounts (unusually frequent or unusually large raises the rating);
• spending pattern (concentration in one high-risk merchant category draws attention);
• payout behaviour (a refund requested without any spending after a top up, a payout address inconsistent with the funding source);
• compliance history (past risk events, penalties, reports or appeals).

High-risk accounts enter "enhanced due diligence": they must explain the source and purpose of funds, and payouts continue only after review by our compliance officer. Ordinary users never notice any of this.

RDVCC operates by reference to the standards of the Financial Action Task Force (FATF), the relevant Hong Kong ordinances and the compliance requirements of our card issuers. 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.