Anti-Money Laundering Policy

4.1 Customer Identification Program

All customers must provide:

• Full legal name and date of birth
• Government-issued photo identification
• Proof of address (utility bill, bank statement, etc.)
• Additional documentation as required by risk assessment

4.2 Enhanced Due Diligence (EDD)

Enhanced verification is required for:

• High-value transactions exceeding established thresholds
• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Business accounts and corporate entities
• Transactions showing unusual patterns

4.3 Ongoing Monitoring

• Regular review of customer transaction patterns
• Periodic updating of customer information
• Continuous screening against sanctions lists
• Monitoring for changes in risk profile

5.1 Automated Monitoring Systems

The Company employs automated systems to:

• Monitor transaction patterns and volumes
• Detect suspicious activities and anomalies
• Screen against sanctions and watchlists
• Generate alerts for manual review

5.2 Transaction Limits

• Daily transaction limits based on customer verification level
• Monthly aggregate limits for stable coin exchanges
• Escalating verification requirements for higher amounts
• Special monitoring for large or frequent transactions

5.3 Suspicious Activity Indicators

Transactions monitored for suspicious patterns include:

• Rapid movement of funds without apparent business purpose
• Structuring transactions to avoid reporting thresholds
• Transactions inconsistent with customer profile
• Use of multiple accounts for related activities
• Unusual geographic transaction patterns

6.1 Sanctions Lists

The Company screens all customers and transactions against:

• OFAC Specially Designated Nationals (SDN) List
• UN Consolidated Sanctions List
• EU Consolidated List
• Local sanctions and prohibited persons lists

6.2 Ongoing Screening

• Real-time screening of all transactions
• Periodic re-screening of existing customers
• Immediate blocking of matched persons or entities
• Regular updates to screening databases

7.1 Required Records

The Company maintains records of:

• Customer identification documents
• Transaction records and supporting documentation
• Suspicious activity reports and investigations
• Training records and policy acknowledgments
• Correspondence with regulatory authorities

7.2 Retention Periods

• Customer records: Minimum 5 years after account closure
• Transaction records: Minimum 5 years after transaction date
• Suspicious activity reports: Minimum 5 years after filing
• Training records: Minimum 3 years

8.1 Suspicious Activity Reporting

The Company will file suspicious activity reports (SARs) with relevant authorities when:

• Transactions appear suspicious or unusual
• Customer behavior raises money laundering concerns
• Required by applicable regulations or thresholds
• Internal investigations warrant reporting

8.2 Currency Transaction Reporting

Large currency transaction reports will be filed as required by local regulations for:

• Stable coin exchanges exceeding specified thresholds
• Cash equivalent transactions above reporting limits
• Aggregate daily transactions meeting reporting criteria

9.1 Employee Training

All employees receive:

• Initial AML training upon hiring
• Annual refresher training programs
• Specialized training for relevant roles
• Updates on regulatory changes and new risks

9.2 Training Topics

Training programs cover:

• AML laws and regulations
• Company policies and procedures
• Suspicious activity identification
• Customer due diligence requirements
• Record keeping obligations

10.1 AML Compliance Officer

The Company designates an AML Compliance Officer responsible for:

• Overseeing AML program implementation
• Conducting risk assessments and policy updates
• Liaising with regulatory authorities
• Managing training and awareness programs
• Investigating suspicious activities

10.2 Management Oversight

Senior management ensures:

• Adequate resources for AML compliance
• Regular policy reviews and updates
• Board-level oversight of AML risks
• Integration of AML considerations in business decisions

11.1 Risk Factors

The Company considers the following risk factors:

• Customer risk (occupation, location, behavior)
• Product risk (stable coins, gift cards, international transfers)
• Geographic risk (high-risk jurisdictions)
• Transaction risk (amount, frequency, complexity)

11.2 Risk Mitigation

Risk mitigation measures include:

• Enhanced due diligence for high-risk customers
• Transaction limits and monitoring
• Restricted services for high-risk jurisdictions
• Regular risk assessment updates

12.1 AML Technology

The Company employs:

• Automated transaction monitoring systems
• Real-time sanctions screening tools
• Customer risk scoring models
• Suspicious activity detection algorithms

12.2 Data Security

• Secure storage of customer and transaction data
• Encryption of sensitive information
• Access controls and audit trails
• Regular security assessments and updates

13.1 Due Diligence on Partners

The Company conducts due diligence on:

• Payment processors and financial partners
• Technology vendors and service providers
• Agent networks and distributors
• Any third parties with access to customer data

13.2 Contractual Requirements

Third-party agreements include:

• AML compliance obligations
• Information sharing requirements
• Audit rights and monitoring provisions
• Termination rights for non-compliance