AML Policy

Nivoda Limited 

Anti-Money Laundering & Counter Terrorist Financing Policy – Web Version 

This webpage provides a high-level, customer-facing overview of Nivoda’s AML/CTF controls and onboarding requirements. Internal procedures are documented and managed separately.

At Nivoda, we are dedicated to building the most trusted B2B marketplace for the jewelry industry. As a global platform facilitating the trade of high-value goods (diamonds, gemstones and jewelry), we operate under strict international Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. Nivoda operates exclusively as a business-to-business marketplace and does not offer services to the general public or end consumers.

This policy outlines our commitment to compliance and the requirements to trade on our platform. Our objective is simple: to ensure our platform is never used for illicit activity. This protects legitimate businesses, safeguards the financial system, and ensures that when you buy or sell on Nivoda, you are dealing with verified, professional entities.

To maintain the integrity of our network, all customers who register to use Nivoda’s platform, either as a buyer or supplier, must undergo our customer due diligence process.

1. Customer Due Diligence: What We Need From You

When you register with Nivoda, you will be asked to complete a Know Your Customer (KYC) or Know Your Business (KYB) verification process. We aim to complete this quickly, but we require cooperation to clear your account for trading and/or credit.

The types of information we require include, but are not limited to, the following:

• Legal Existence: Certificate of Incorporation or Business Registration, or equivalent official record issued by a competent authority.
• Identity: A valid, government-issued photo ID (e.g. Passport/ Driver’s License) for the account administrator.
• Beneficial Ownership: A valid, government-issued photo ID (e.g. Passport/ Drivers License) for any individual who owns or controls 25% or more of the company (Ultimate Beneficial Owner), or otherwise exercises effective control.
• Address: Proof of operating address (e.g., utility bill, bank statement, lease agreement, or official registry extract). You may also consult our Address Policy. 
• Industry Connection: Evidence demonstrating active involvement in the jewelry, diamond, or gemstone trade (e.g. trade licences, invoices, supplier agreements, or company website).

Note: In higher-risk cases, we may request additional information such as source of funds/source of wealth, transaction rationale, or supporting trade documentation in accordance with international and local laws & regulations. 

2. Cashless Policy & Payments

Nivoda facilitates trade in high-value goods and applies DPMS-aligned controls where applicable. This includes but is not limited to: 

• We do not accept cash payments under any circumstances.
• All transactions must be settled via traceable banking channels or approved payment processors (e.g., credit card, bank transfer).
• We do not offer consumer credit, only business credit.
• Third-party payments (payments made by someone other than the business or account holder) may require evidence of the underlying business relationship and source of funds. Nivoda reserves the right to reject such payments if the relationship cannot be adequately verified.

3. Screening 

Nivoda screens its customers, suppliers, and beneficial owners against global sanctions, politically exposed person (PEP), watchlist, and adverse media databases, including but not limited to the United Nations (UN), U.S. Office of Foreign Assets Control (OFAC), European Union (EU), and UK sanctions lists.

Nivoda does not engage in business with:

• Individuals or entities subject to international sanctions or restrictive measures;
• Individuals or entities located in jurisdictions subject to comprehensive sanctions or otherwise prohibited under applicable law;
• Individuals identified as politically exposed persons (PEPs), or entities owned or controlled by PEPs, where enhanced due diligence and senior management approval do not sufficiently mitigate the associated risk.
  
  

In addition, Nivoda reserves the right, at its sole discretion, to decline, restrict, suspend, or terminate any customer or supplier relationship based on compliance, legal, reputational, or business risk considerations, including adverse media or other risk indicators, even where minimum legal or regulatory requirements may otherwise be met. 

4. Ongoing  Monitoring

As part of our commitment to protecting our platform and users from financial crime—including fraud, circular trading, money laundering, and other forms of misuse—Nivoda conducts ongoing monitoring of customer activity. As part of this monitoring, we may request additional information or documentation to verify transactions or assess risk. 

Nivoda reserves the right to decline or suspend transactions made through its platform, as well as terminate relationships with customers that fall outside of its approved risk appetite. 

5. Data Protection and Privacy

We understand that the documents you provide contain sensitive data. Therefore, you can trust us that:

• Data collection is limited to what is required for legitimate business purposes. 
• All information provided for verification is encrypted, stored securely, and accessible only to authorized staff. 
• We retain records for the minimum statutory period required by law and strictly adhere to GDPR standards and in accordance with Nivoda Privacy Notice.

If you have questions about how we process your personal data, please reach out to us at: [email protected] 

6. Reporting Suspicious Activity

Nivoda is legally required to report any knowledge or suspicion of money laundering or terrorist financing to the relevant Financial Intelligence Units (FIUs) in accordance with applicable law. Nivoda operates a zero-tolerance approach to any attempt to circumvent its AML/CTF controls, falsify documentation, or misuse the platform. In line with statutory “tipping-off” prohibitions, Nivoda is not permitted to disclose whether a report has been made, is being considered, or is under review, and will not discuss such matters with customers or third parties.