These are the measures Apolo publishes on its regulation page.
Measures
KYC and KYB
Identity verification for every customer before account activation.
Continuous monitoring
Transaction monitoring, including blockchain transactions.
Sanctions screening
Screening against OFAC/SDN, UN and EU lists.
Reporting
Reports to the UIF in Costa Rica and FinCEN in the United States as the regulation requires.
How it is applied
1
Due diligence
Customer due diligence, and enhanced due diligence by risk profile.
2
Monitoring
Ongoing monitoring of transactions and customers.
3
Independent review
Periodic independent review of the program.
Questions about the AML policy
Where is the contractual detail?
In the regulatory compliance section of each part of the Terms (Spanish).
Who answers regulatory questions?
The compliance officer, through compliance@apolo.io.
This page summarizes the public information on the regulation page; it is not the full policy document. Initial version, pending legal review. The full text is yet to be published.
Who stands behind your money
Who holds it
Digital assets are held in custody with BitGo. Balances in traditional currency are held with regulated partners.
Who supervises
Apolo Capital LLC is registered as an MSB with FinCEN in the United States. In Costa Rica, SUGEF supervises Apolo Capital Limitada only for anti-money-laundering matters.
What it does not cover
SUGEF does not supervise Apolo's solvency or security, and balances are not backed by the Guarantee Fund. Digital assets can lose value.