AML, KYC, and verification
Identity and compliance controls that exist in the product today — and what is not built yet. Last updated: September 19, 2026
Last updated: September 19, 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
| Control | Status today |
|---|---|
| Account sign-in (Apple, Google, email / Privy) | Live |
| @alias required to post or take a P2P trade | Live |
| Linked wallet required to trade or take crypto at POS | Live |
| Operational caps (active ads, active taker orders, ad price band, min 1 USDC) | Live |
| Merchant marketplace application and admin review | Live (badge / listings — not a crypto gate) |
| Business registration (name, country, tax id) for POS | Live |
| Document KYC (government ID, liveness) to use wallet or P2P | Not live |
| Automated KYB gate on merchant cash-out | Not live |
| Sanctions / PEP screening in the product | Not live |
| Automated transaction monitoring or SAR workflow in the product | Not live |
| Partner on-ramp KYC | Not live (any in-app on-ramp KYC screen is not a production provider) |
1. Account, not a regulated KYC onboarding
You need an account to use the wallet, P2P, and POS. 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.
P2P also requires an @alias and a wallet address we can bind to the account. Those are anti-abuse and operational gates, not identity verification.
Opening a POS business collects trade name, country, and a tax id when the flow asks for it (for example RNC). That is business onboarding for the floor, 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, does not unlock crypto POS, 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: no document KYC today
Anyone with a signed-in account, an alias, and a wallet can post or take a P2P ad, send or receive USDC, and — if they operate a POS whose owner has a wallet — take crypto at checkout.
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
Because P2P USDC sits in a per-trade on-chain escrow and merchant POS USDC goes straight to the owner’s wallet, Nodo is not holding customer crypto in a platform omnibus. Fiat in a P2P 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 already being live.
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:
- The owner submits bank details and a DOP amount from the business wallet.
- Nodo may ask for additional verification (including the marketplace application or documents we request by email) before sending fiat.
- 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. What we may ask for later
We may introduce document KYC, sanctions checks, limits, or extra steps for P2P, wallet sends, POS crypto, or cash-out. 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.
7. Contact
Questions about this page: info@nodoia.app.
Nodo AI, Inc., 131 Continental Dr, Suite 305, Newark, DE 19713, United States.