AML/CTF and KYC Policy

Last updated: February 2026

1. Introduction

Novu Tech Ltd ("Novudi") is committed to the highest standards of Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) compliance. This policy outlines the measures we take to prevent our services from being used for money laundering, terrorist financing, or other illegal activities.

2. Regulatory Framework

Novudi operates in compliance with:

• Bulgarian Measures Against Money Laundering Act
• EU Directive 2015/849 (Fourth Anti-Money Laundering Directive)
• EU Directive 2018/843 (Fifth Anti-Money Laundering Directive)
• Financial Supervision Commission of Bulgaria regulations
• FATF Recommendations

3. Customer Due Diligence (CDD)

Individual Clients

For individual clients, we require:

• Government-issued photo identification (passport or national ID)
• Proof of residence (utility bill, bank statement, or government correspondence not older than 3 months)
• Selfie/video verification
• Source of funds documentation (when applicable)

Corporate Clients

For corporate clients, we additionally require:

• Certificate of incorporation
• Articles of association
• Register of shareholders and directors
• Identification of Ultimate Beneficial Owners (UBOs)
• Proof of registered address

4. Enhanced Due Diligence (EDD)

Enhanced due diligence measures are applied for:

• Politically Exposed Persons (PEPs)
• Clients from high-risk jurisdictions
• Complex or unusual transactions
• High-value transactions exceeding established thresholds

5. Transaction Monitoring

We continuously monitor transactions for suspicious activity, including:

• Unusual transaction patterns
• Transactions that do not match the client's profile
• Rapidly increasing transaction volumes
• Transactions involving known high-risk addresses

6. Blockchain Analysis

We utilize blockchain analysis tools to screen cryptocurrency transactions and addresses for connections to:

• Darknet markets
• Sanctioned entities
• Stolen funds
• Mixer and tumbler services
• Known fraudulent activities

7. Suspicious Activity Reporting

When suspicious activity is identified, we:

• File Suspicious Activity Reports (SARs) with the Bulgarian FID (Financial Intelligence Directorate)
• Freeze related accounts pending investigation
• Cooperate fully with law enforcement authorities

8. Sanctions Screening

All clients and transactions are screened against:

• EU sanctions lists
• UN sanctions lists
• OFAC (Office of Foreign Assets Control) lists
• National sanctions lists

9. Record Keeping

We maintain records of all customer identification documents, transaction records, and compliance activities for a minimum of 5 years after the end of the business relationship, or as required by applicable regulations.

10. Training

All employees receive regular training on AML/CTF procedures, including how to identify and report suspicious activities.

11. Contact

For questions about this policy, please contact our compliance team at:

Email: support@novudi.com
Address: ul. San Stefano 22, Office 16, San Stefano Plaza, 1504, Sofia, Bulgaria