AML / KYC Policy

Version 0.1-draft · Effective from 2026-04-20

Draft — compliance-officer review pending. Procedures bind internally regardless.

1. Scope

We apply anti-money-laundering (AML) and know-your-customer (KYC) controls on every account funding the platform with real capital.

2. Customer due diligence

Verification of email, phone, government-issued ID, and residential address. Enhanced due diligence (source of funds, source of wealth) for higher deposit tiers or risk-flagged jurisdictions.

3. Transaction monitoring

Automated rules flag unusual deposit patterns, rapid churn, and mismatches between declared source of funds and observed behavior. Flagged cases escalate to compliance review.

4. Reporting

We file suspicious activity reports with the relevant financial intelligence unit when our review determines statutory thresholds have been met.

5. Sanctions screening

Customers, beneficiaries, and counterparties are screened against OFAC, EU, UK, and UN consolidated lists at onboarding and on an ongoing basis.