Anti Money Laundering

1. Purpose & Applicability

• To prevent misuse of our platform for money laundering, terrorist financing, fraud, or illicit activity.

• Applies to all customers, users, merchants, agents, business lines, and relevant staff.

2. Regulatory Framework

This policy aligns with global best-practice and regional AML/KYC regimes, including:

• FATF recommendations

• U.S. Bank Secrecy Act (FinCEN), including the Patriot Act

• EU AMLD6

• U.K. Money Laundering Regulations

• Hong Kong OSCO / AMLO

• Other applicable frameworks where operations or clients exist

3. Definitions & Roles

• Customer: Any individual or legal entity interacting with services, including franchises, and administrators.

• Beneficial Owner (BO): Natural person(s) controlling ≥ 25% ownership in an entity customer.

• Politically Exposed Person (PEP): Individuals in prominent public functions or their close associates.

• Principal Officer: Appointed person responsible for overall AML compliance, filing Suspicious Activity Reports (SARs), and liaising with FIUs.

• Compliance Team: Responsible for ongoing monitoring, risk assessments, training, and audits.

• Board: Oversees and approves this policy annually.

4. Customer Risk Assessment

4.1 Risk-Based Approach (RBA)

Customers are assigned a baseline risk score—Low, Medium, or High—based on:

1. Geographic Risk

2. • High-risk jurisdictions (e.g., FATF grey/blacklist)

   • Special PEP screening when relevant jurisdictions are involved

3. Customer Type

4. • Retail individuals (typically low–medium risk)

   • Corporates, trusts, and partnerships (inherently higher risk)

5. Business Profile & Activity

6. • Share purchasers (investment nature)

   • High-volume or cross-border server hosting clients

7. Transaction Patterns

8. • One-off high-value cross-border invoice

   • Repetitive, rapid, or multi-jurisdiction deposits/withdrawals

9. Sanctions/Adverse Media

10. • Continuous watchlist and media screening

4.2 Risk Scoring

Risk Level	Parameters	Measures
Low	Individuals in stable geos, invoices < $10K/month	Standard CDD; periodic review every 5 yrs
Medium	invoices > $10K/month, entity accounts, cross-border	EDD; KYC reviews every 2–3 yrs
High	PEPs, sanctioned/named entities, high-risk geographies	EDD+, senior approval, annual KYC refresh

5. Customer Identification & Verification (CIP / CDD)

5.1 Individual Customers

Required Documents:

• Government-issued photo ID (passport, driver’s license)

• Proof of address (utility/phone bill ≤ 3 months old)

• Selfie or liveness check via biometric solution

Verification:

• Use automated ID verification (e.g., facial match); fallback to manual if needed.

• Sanctions, PEP, and adverse media screening pre-onboarding.

5.2 Business (Entity) Customers

Required Documents:

• Certificate of Incorporation / Registration

• Memorandum & Articles or equivalent

• List of directors + verified IDs

• UBO declaration with ≥ 25% share confirmed via identity docs

• Proof of address (entity)

• Bank statement or ownership documents

Process:

• Validate UBOs and board members via ID and address proofs.

• Politically exposed status and sanctions of directors/UBOs checked.

• Ongoing adverse media, sanctions screening.

6. Ongoing Monitoring & Transaction Surveillance

• Real-time transaction monitoring with threshold alerts (e.g., > $10,000 / €10,000).

• Behavioral anomaly detection—unusual geographic changes, frequency spikes, cross-border patterns.

• System flags for atypical deposit sources or known bitcoin/wallet risk.

• Monthly review of elevated-risk accounts by Compliance Team.

• Sanction list rescreening quarterly or with updates.

7. Enhanced Due Diligence (EDD)

Triggered for:

• High-risk geographies, PEPs, shell companies, complex ownership structures, large purchases.

EDD Requirements:

• Detailed source-of-funds (bank statements, income documents).

• High-resolution ID, certified translation (if non-English).

• Interview process (in person or video).

• Senior Compliance Officer sign-off required.

8. Sanctions & PEP Screening

All new and existing clients and transactions screened against:

• United Nations, EU, U.K., U.S. (OFAC), HKMA, and locally relevant lists.

• Repeat screenings quarterly or upon list updates.

• Immediate account suspension for hits pending investigation.

9. Suspicious Activity Reporting (SAR)

• Any suspicious transaction filed as SAR within 7 days of detection.

• Guidelines:

• • Structuring/smurfing behavior

  • UBO concealment, false documentation

  • Rapid buy-sell without rationale

• Compliance logs incident, escalates to Principal Officer, submits SAR to FIU.

• No tipping-off allowed—employees trained accordingly.

10. Record Retention

• Identification documents: retain for 5 years post-account closure.

• Transaction logs (purchases, hosting payments): 5 years retention.

• SARs / Investigations: archived securely for 5+ years.

• Stored with encryption; access restricted by role-based controls.

11. Governance & Accountability

• The Board of Directors oversees policy approval, updates, and compliance.

• Principal Officer accountable for execution and regulatory liaison.

• Compliance Team performs daily screening, monitoring, and internal audits.

• External audit once per year; risk-based internal audits quarterly.

12. Training & Culture

• AML/KYC onboarding for all staff, contractors, server purchasers.

• Refresher training at least annually or with legal updates.

• Specialized sessions in fraud detection, PEP screening, sanctions, mobile payments, high-risk money flows.

13. Technology & Integration

• Biometric liveness from automated ID verification providers.

• Sanctions/PEP screening through reputable data providers.

• Transaction monitoring system with AI-based anomaly detection.

• Investor dashboard for secure interaction, logs preservation.

• Ongoing discussion with third-party cybersecurity consultants (per site note).

14. Policy Review & Update

• Official annual review by Compliance Team and Legal Counsel.

• Immediate revision triggers:

• • Regulatory changes (e.g., new EU rules)

  • Emerging financial crime techniques

  • Product expansions

  • Technological/logistics changes (e.g., third-party integrations)

15. Governance Matrix

Role	Responsibility
Board of Directors	Policy approval and strategic oversight
Principal Officer	SAR filing, external reporting, policy implementation
Compliance Team	KYC verification, monitoring, audit, reporting
IT / Security Team	Ensuring system integrity, encryption, audit logs
All Employees	Flagging AML/CTF concerns, completing training

16. Annex – Risk Indicators & Red Flags

• High-value purchases from obscure shell entities

• Use of multiple IP addresses for same customer

• Attempts to obscure UBO structure or beneficial ownership

• Multiple small payments aggregating into large deposits

• Transfers originating from high-risk jurisdictions

• Discrepancy between customer profile and transactional behavior