AML / CFT Policy
Introduction
We are NovaBridge Tech OÜ, a company incorporated in Estonia under registry code 17390133, with a registered address at Harju maakond, Tallinn, Lasnamäe linnaosa, Võru tn 11, 13612, Estonia.
NovaBridge Tech OÜ operates the brand Nodomono and manages the main website: https://nodomono.com (“Website”, “us”, “we”, “our”, “Company”, “Nodomono”).
Nodomono functions as an online platform providing digital gift cards and mobile top-up vouchers.
This Policy outlines procedures for preventing money laundering and terrorist financing, as well as complying with international sanctions. It establishes the rules for screening Clients and their transactions to detect, prevent, and report any activity that may relate to Money Laundering or Terrorist Financing.
Regulatory Framework
The Company’s AML and CTF system is designed to comply with all relevant legislation and guidance in the jurisdictions in which we operate. This includes (but is not limited to) the Estonian Money Laundering and Terrorist Financing Prevention Act, the EU AML Directives (4AMLD, 5AMLD, 6AMLD), Regulation (EU) 2015/847, GDPR (Regulation EU 2016/679), and the FATF Recommendations.
1. Definition of certain terms
Identification data
For natural persons: all first names and surname, personal identification number or, if unavailable, date of birth, place of birth, sex, permanent or other residence, and citizenship.
For legal entities: legal name, identifying mark or number, registered address, business registry number or foreign equivalent, and identification data of individuals acting as governing members.
Money laundering
Any activity aimed at concealing or obscuring the illegal origin of financial gains resulting from criminal actions. This may include:
• transforming or transferring assets known to originate from criminal activity in order to hide their origin or assist another party in evading legal consequences;
• concealing or disguising the true nature, source, location, ownership, or movement of property originating from criminal activity;
• acquiring, holding, or using property known to originate from criminal activity;
• acting as part of an organized group for the purpose of conducting any of the above activities.
Terrorist financing
The collection or provision of funds or assets with knowledge that they will be used (even partially) for terrorism, terrorist attacks, related criminal acts, or support of individuals preparing such acts. This also includes financing the distribution of weapons of mass destruction.
Non-transparent ownership structure
A situation where identifying the beneficial owner of a client is not possible based on registry excerpts, authenticated incorporation documents, or other reliable sources.
A structure is *not* considered non-transparent if the client is publicly traded or otherwise meets established criteria of transparency.
Transaction
Any act carried out by the Company on behalf of a client that results in disposal of client assets or provision of a service, including payment operations.
Business relationship
A contractual relationship between the Company and a Client where it is clear from the outset that transactions will occur repeatedly. Entering into a third consecutive transaction automatically indicates a recurring relationship.
Politically Exposed Person (PEP)
A natural person who holds or has held a prominent public position (nationally or internationally). This includes heads of state, senior political figures, high-ranking officials, judges, military leaders, central bank board members, ambassadors, and individuals closely associated with them.
Related persons, close associates, and individuals benefiting from arrangements connected to a PEP also fall under this definition.
Proof of identity
A government-issued ID card, passport, driver’s license, or any similar document that contains the holder’s full name, date of birth, and photograph.
Client order
An instruction submitted by the client requesting execution of a payment or any other action involving the client’s funds.
Beneficial owner
A natural person who ultimately owns or controls a legal entity or arrangement, either directly or indirectly, typically through:
• ownership of more than 25% of shares or voting rights;
• entitlement to at least 25% of profits;
• control through other means or positions of authority.
Country of origin
The country from which an individual or legal entity originates, resides, or is registered.
2. The reason for verification
The Company carries out identity verification when the volume of a Client’s orders exceeds EUR 1,000 or when any activity appears suspicious.
3. Risk assessment and the risk profile of a customer
The Company evaluates all Clients to determine their risk of involvement in money laundering or terrorist financing activities. Based on the information gathered during identification, a risk level is assigned, and conditions may be applied restricting or terminating the relationship.
3.1 Risk categorisation of types of clients with regard to risk factors
Risk indicators include, but are not limited to:
• inability to establish the beneficial owner;
• unclear purpose of the business relationship;
• unclear or unverifiable source of funds (e.g., cash winnings, cash gifts);
• inactive or non-operational companies;
• entities based in offshore jurisdictions or controlled by offshore parties;
• suspicion that a client is acting on behalf of another party;
• identical contact information used by multiple unrelated clients;
• residential address registered at an authority;
• indicators of suspicious transactions;
• client or beneficial owner located in a high‑risk jurisdiction;
• business activity inherently associated with higher AML/CTF risks;
• complex or unusual ownership structure.
Some indicators-such as unverifiable source of funds or presence on sanctions lists-are treated as major risk signals.
3.2 Customer Risk Assessment and Due Diligence Measures
The Company assesses each client’s risk level based on:
• profile and background,
• geographical exposure,
• nature and size of transactions,
• industry and activity type,
• links to high-risk categories.
Based on these factors, customers are categorised as Low, Medium, or High risk.
Low-Risk Customers
Clients whose activity and background present minimal AML concerns. Such clients may undergo Simplified Due Diligence (SDD) as permitted by law.
Medium-Risk Customers
Clients who do not clearly fall under low or high risk. Standard Due Diligence (NDD) applies.
High-Risk Customers
Clients with elevated risk indicators, including PEPs, clients from high-risk jurisdictions, and those with unusual or complex transaction behaviors. Enhanced Due Diligence (EDD) applies.
Simplified Due Diligence (SDD)
Performed when risk is demonstrably low and exemptions apply.
Enhanced Due Diligence (EDD)
Performed where risk is high. Includes deeper identity checks, source-of-funds verification, and ongoing monitoring.
Normal Due Diligence (NDD)
Applied when risk level is average.
Client risk profile
The Company uses three AML risk profiles:
• Profile 1 – Non-risk profile: no AML concerns;
• Profile 2 – Risk profile: identifiable AML risks, but still acceptable;
• Profile 3 – Unacceptable profile: AML risks that prohibit entering or continuing a business relationship.
4. Rules of the individual approach to a client
The Company ensures clear differentiation between a natural person acting independently and a person acting on behalf of a legal entity. Orders submitted by one party cannot be mixed, confused, or split with those of another.
5. International Sanctions and PEPs
The Company must comply with all applicable international sanctions. Enhanced attention is paid to all Clients and their activities to determine whether they may be subject to sanctions.
PEPs present higher AML risk due to increased exposure to corruption or bribery. Although being a PEP is not illegal, the Company does not onboard PEPs or individuals listed under sanctions.
6. Record keeping
The Company maintains records of Clients and their orders for at least five years after termination of the Business Relationship, in line with legal requirements.
7. Training program
The Company provides regular AML/CTF training to ensure staff understand AML risks, follow internal procedures, and are able to detect and report unusual activity. Training is adapted to each role’s responsibilities and level of exposure to risk.
8. Amendment of the Policy
The Company reviews this Policy at least annually and may update it at any time. The latest version will always be published on the official website: https://nodomono.com.
Clients should review the Policy periodically. Continued use of our services after updates constitutes acceptance of the revised document.