1. AML Compliance Framework

Our AML program is designed to detect and prevent money laundering activities through:

• Customer Due Diligence (CDD) procedures
• Enhanced Due Diligence (EDD) for high-risk customers
• Ongoing monitoring of customer transactions
• Suspicious Activity Reports (SARs) when required
• Record keeping and documentation
• Regular staff training and awareness programs

2. Know Your Customer (KYC) Requirements

All customers must complete our KYC verification process before accessing our services:

Basic Verification Requirements:

• Full legal name as it appears on government ID
• Date of birth and nationality
• Residential address with proof of address
• Government-issued photo identification
• Source of funds declaration

Enhanced Verification (for higher limits):

• Financial statements or proof of income
• Business registration documents (for corporate accounts)
• Beneficial ownership information
• Additional identification documents
• Video verification interview (if required)

3. Prohibited Customers and Activities

We prohibit the following customers and activities:

Prohibited Customers:

• Individuals or entities on sanctions lists
• Politically Exposed Persons (PEPs) without enhanced due diligence
• Customers from high-risk jurisdictions
• Anonymous or pseudonymous accounts
• Customers who refuse to provide required documentation

Prohibited Activities:

• Money laundering and terrorist financing
• Structuring transactions to avoid reporting requirements
• Using the platform for illegal activities
• Creating multiple accounts to circumvent limits
• Providing false or misleading information
• Mixing or tumbling services

4. Transaction Monitoring

We continuously monitor all transactions for suspicious activity:

• Automated transaction monitoring systems
• Manual review of flagged transactions
• Analysis of transaction patterns and behavior
• Regular audits and compliance checks
• Blockchain analysis and screening

5. Reporting Requirements

We are required to report certain activities to relevant authorities:

• Suspicious transactions above threshold amounts
• Cash transactions exceeding reporting limits
• Attempted transactions by prohibited persons
• Failed verification attempts
• Unusual or unexplained transaction patterns

6. Record Keeping

We maintain comprehensive records as required by law:

• Customer identification and verification documents
• Transaction records and supporting documentation
• Suspicious activity reports and related investigations
• Correspondence and communications with authorities
• Training records and policy updates

Records are retained for a minimum of 5 years or as required by applicable law.

7. Risk Assessment

We conduct regular risk assessments considering:

• Customer risk factors (geography, occupation, transaction patterns)
• Product and service risks
• Geographic risks based on jurisdiction
• Delivery channel risks
• Regulatory and compliance risks

8. Sanctions Screening

We screen all customers and transactions against relevant sanctions lists:

• OFAC (Office of Foreign Assets Control) lists
• UN Security Council sanctions lists
• EU consolidated sanctions list
• Other relevant national and international sanctions
• Real-time screening of new transactions

9. Training and Awareness

Our staff receives regular AML training covering:

• AML laws and regulations
• Internal policies and procedures
• Red flags and suspicious activity indicators
• Customer due diligence requirements
• Reporting obligations and procedures

10. Cooperation with Authorities

We fully cooperate with law enforcement and regulatory authorities:

• Responding to information requests
• Providing transaction records and documentation
• Freezing accounts when legally required
• Participating in investigations
• Implementing regulatory guidance and updates

11. Policy Updates

This AML Policy is reviewed and updated regularly to ensure compliance with evolving laws and regulations. Changes will be communicated to customers through our website and other appropriate channels.

12. Contact Information

For questions about our AML Policy or to report suspicious activity: