Risk Control Policy

Effective Date: June 18, 2026

Dotva is a financial management platform. As part of that service, we provide virtual cards as a spending instrument for teams and organizations. Like all financial tools, their use is subject to card network rules, issuer requirements, and applicable regulations. This policy describes the risk controls that govern how these tools may be used and what happens when violations occur.

1. Prohibited Activities

The following activities are strictly prohibited when using Dotva's financial tools:

Illegal Transactions

• Money laundering
• Terrorism financing
• Fraudulent activities
• Any transaction that violates local or international law

Platform Abuse

• Attempting to bypass our security measures
• Creating multiple accounts to circumvent restrictions
• Exploiting system vulnerabilities
• Any activity that may compromise the integrity of our platform

Merchant Abuse

• Unauthorized transactions
• Any activity that may harm our merchant partners

Card Network Violations

• Violating card network rules and regulations
• Circumventing card network security measures
• Abusing card network services

2. Prohibited Merchant Categories (MCC)

Virtual cards issued via Dotva may not be used at merchants in the following categories:

Transactions at prohibited merchant categories are subject to compliance review. Repeated violations may result in card closure and account termination.

3. Automated Risk Rules

Dotva's risk engine evaluates every card transaction in real time. The rules below are active on all accounts as of the effective date above. Thresholds are managed by Dotva and may be adjusted without notice.

How it works

• Real-time evaluation — every transaction, including $0 pre-authorizations, triggers a rule check.
• Post-transaction enforcement — our engine acts on subsequent transactions after a rule fires; it cannot reverse the transaction that triggered it.
• Independent rules — each rule evaluates separately; when multiple rules fire simultaneously, the strongest action applies.

Enforcement actions

Active rules (effective June 18, 2026)

Rule notes

Consecutive failures: The failure counter resets upon any successful authorization, settlement, or refund. Occasional declines during normal use will not trigger card closure. The per-decline penalty fee is the primary deterrent; closure is a last resort for cards that sustain prolonged failure without corrective action.

Post-closure penalty fees: Even after a card is closed, delayed or force-posted charges from merchants continue to incur the $0.15 fee until the card is removed from the merchant's billing system. The only way to stop recurring charges is to cancel the subscription or remove the card directly with the merchant.

Blacklisted merchants: Certain merchants are known to settle amounts exceeding the original authorization. Cards used at these merchants are closed upon the first transaction as a protective measure. Contact support if you believe a merchant has been incorrectly classified.

4. Withdrawal Policy

4.1 Withdrawal requests are processed manually by Dotva compliance staff within 7–15 business days.

4.2 Withdrawal fees:

4.3 Withdrawals may be delayed or refused if:

• The workspace has active risk flags or a pending compliance review
• There are outstanding fee obligations (including a negative wallet balance)
• The requested amount exceeds the available cleared balance

4.4 Withdrawals are processed in USDT to the address specified in the request. Only one pending withdrawal request is allowed per workspace at a time.

5. Regulatory Compliance

Our platform strictly adheres to applicable financial regulations, including but not limited to:

• Bank Secrecy Act (BSA)
• Anti-Money Laundering (AML) regulations
• Office of Foreign Assets Control (OFAC) sanctions
• Payment Card Industry Data Security Standard (PCI DSS)
• Card network rules (Visa program requirements)

Dotva may be legally required to report transactions to relevant authorities, including Financial Intelligence Units (FIU), tax authorities, and law enforcement when served with valid legal process. We will notify affected users of legal disclosures where permitted by law.

6. Enforcement Actions

Violations of this policy will result in immediate action, including one or more of the following:

• Account suspension — platform access is restricted pending investigation
• Freezing of associated funds — wallet balance is held until the investigation concludes
• Investigation of suspicious activity — our compliance team will review the account
• Financial penalties — fees assessed per Section 3
• Recovery of financial losses — Dotva reserves the right to recover losses caused by policy violations
• Additional penalties for repeat violations — escalating consequences for continued non-compliance

Suspended accounts retain their wallet balance. Funds will be returned (minus outstanding fees and penalties) after the investigation is complete.

7. Updates to This Policy

Dotva reserves the right to update this policy as required by regulatory changes or card network rule updates. Material changes will be communicated with 30 days' notice where possible. Automated risk rule thresholds may be adjusted at any time without prior notice.

8. Contact

For risk, compliance, and support inquiries: support@dotva.io