KYC/AML Disclosure

This disclosure explains the Know Your Customer ("KYC") and Anti-Money Laundering ("AML") requirements that apply when you enroll in Milli Elite Card features.

1. When KYC Applies

KYC is only required for Milli Elite Card features. Core Milli features, including Milli Tax Vault planning tools, mileage tracking, expense management, reports, and Milli AI, do not require identity verification beyond standard account sign-up. KYC is required to meet financial regulations and to keep your money safe when card issuing or money movement is involved.

2. What We Collect

To verify your identity, Milli and its partner bank collect: full legal name; date of birth; residential street address (P.O. boxes are not accepted); Social Security number or Individual Taxpayer Identification Number; and, where needed, an image of a valid, unexpired government-issued photo ID and supporting documents. See our Patriot Act CIP Notice.

3. How We Verify

Information is verified using documentary and non-documentary methods, which may include comparing your information with consumer reporting agencies, public records, and identity verification providers, and analyzing ID document authenticity. If we cannot verify your identity, we may request additional documentation or decline enrollment.

4. Sanctions and Watchlist Screening

All Elite Card applicants are screened against the U.S. Treasury Office of Foreign Assets Control ("OFAC") Specially Designated Nationals and Blocked Persons List and other government lists, at enrollment and on an ongoing basis.

5. Ongoing Monitoring

Card accounts are subject to ongoing transaction monitoring to detect and prevent fraud, money laundering, and other financial crime. We may request additional information, place holds, or restrict or close accounts as required by law or our partners' programs. We may be prohibited by law from telling you why.

6. How Your Information Is Protected

Identity information is encrypted in transit and at rest, access is restricted to authorized personnel, and records are retained for at least five years after account closure as required by the Bank Secrecy Act. See our Privacy Policy and Data Security Policy.

See our BSA/AML Program Statement and FinCEN Compliance Statement.