AML, KYC, and verification

Last updated: 27 October 2026

This page describes identity and financial-crime controls as implemented in the current product. It is part of the Terms of Use. How funds move is in Wallet and custody.

Nodo AI, Inc. identifies itself in the product as a Money Services Business registered with FinCEN (United States). This page is not an AML program manual. It states what the apps and API actually enforce so we do not over-claim.

What is live vs still being finalized

1. Account, not a regulated KYC onboarding

You need an account to use the shop and the wallet. Person-to-person USDC trading is no longer offered as of 27 October 2026. We know the identifiers your sign-in provider gives us (and the email or name you enter). That is account authentication, not a government-ID KYC program.

A P2P trade opened before that date also required an @alias and a wallet address we can bind to the account. Those were anti-abuse and operational gates, not identity verification.

Opening a shop collects a name, a country, and a tax id when the flow asks for it (for example RNC), plus the WhatsApp number for orders. That is shop signup, not a payment-services KYB file.

2. Merchant verification is a marketplace application

The in-product Verify / Verified flow is a merchant application: brand, category, phone, and how the business handles catalog and photos. An admin approves or rejects it. A cédula image is not required in the current wizard.

That badge is for marketplace / listing visibility. In the current code it does not unlock P2P and does not automatically unlock bank cash-out.

Nodo may still ask a business for more documents before completing a merchant cash-out. That review, when it happens, is operational. It is not an automated KYB check in the app today.

3. P2P and wallet: document KYC not mandatory

Person-to-person USDC trading is no longer offered as of 27 October 2026. Before that date, anyone with a signed-in account, an alias, and a wallet could post or take a P2P ad and send or receive USDC.

While a trade is open, the seller can ask the buyer to verify their identity with an outside provider. The result is marked on the trade. It is a tool for the seller, not a general requirement to trade.

To use the wallet or P2P, we do not currently require:

• Passport, cédula, or driver’s license
• Liveness or selfie matching
• Proof of address
• Source-of-funds questionnaire

Do not treat “you can trade” as “Nodo has verified this person.” Counterparties should use the trade chat, the on-chain escrow, and their own judgment.

4. AML posture that follows from custody

Person-to-person USDC trading is no longer offered as of 27 October 2026. USDC from a trade opened before that date sits in a per-trade on-chain escrow, and wallet USDC sits at the address of the person who signs in. Nodo is not holding customer crypto in a platform omnibus. Fiat in such a trade moves bank-to-bank between the two users. Fiat in a merchant cash-out is a separate, manual request to Nodo (see Wallet and custody).

What that means for this page:

• The crypto legs are public Base transactions we can index.
• We store P2P ad and order records, including payout bank or remittance details the parties enter, and the trade chat (text and images).
• We can suspend or close an account under the Terms if we see fraud, abuse, or legal risk.
• We do not currently run automated sanctions screening or a transaction-monitoring case system in the product. Building those controls is not the same as the escrow that was offered before 27 October 2026.

If an authority lawfully requires records or a freeze we can actually effect (account, ads, new escrows), we will follow the law. We cannot seize USDC that already sits in an open escrow clone; the contract only moves that pot by seller release, seller cancel (before paid), or arbiter resolve after a dispute.

5. Merchant cash-out and KYB

Cash-out is a differentiated flow: business wallet only, Nodo as DOP counterparty, settlement still being finalized.

Until automated KYB is live, treat it as:

1. The owner submits bank details and a DOP amount from the business wallet.
2. Nodo may ask for additional verification (including the marketplace application or documents we request by email) before sending fiat.
3. Nodo may refuse, delay, or cancel a request.

A “Verified” badge is not, by itself, a promise that a cash-out will be paid.

6. USD and EUR accounts

Dollar and euro accounts are opened through Bridge, Nodo’s accounts partner. These controls are live:

1. Holder verification. A person passes KYC with a document; a company passes KYB. Bridge does the verification with its identity provider. Without approved verification the account does not open, and the verified name is the holder.
2. Approval of every move. Sends and conversions are confirmed with Face ID or a passkey. A new device waits 24 hours before it can approve.
3. Limits. There is a monthly limit for sending to other people’s accounts and a higher one for sending to your own accounts. An increase is requested from the app and reviewed by the Nodo team.
4. Review. The Nodo team gets alerts when the depositor’s name does not match the holder, when a large deposit arrives, and when a limit is reached, and reviews activity on a monitoring desk. Nodo may ask for information, decline a send, or close an account.
5. Flagged bank accounts. Nodo refuses sends to bank accounts that Bridge flags as invalid.

7. What we may ask for later

We may introduce document KYC, sanctions checks, limits, or extra steps for wallet sends or cash-out. Person-to-person USDC trading is no longer offered as of 27 October 2026. When a step is actually required in the product, we will say so in the flow and update this page.

Until then, do not assume those checks exist.

8. Contact

Questions about this page: info@nodoia.app.

Nodo AI, Inc., 131 Continental Dr, Suite 305, Newark, DE 19713, United States.