AML / KYC Policy

1. Purpose & Scope

We are committed to preventing use of the Platform for money laundering, terrorist financing, sanctions evasion, fraud, and other financial crime.

This Policy applies to account holders, visitors who initiate onboarding, and (where relevant) counterparties interacting with Platform payment rails.

2. Risk-Based Approach

Controls are applied on a risk-based basis. Higher-risk users, corridors, or behaviors may trigger enhanced due diligence (EDD), transaction limits, or rejection of activity.

Risk factors may include geography, product type, transaction velocity, source of funds indicators, and adverse media or sanctions hits.

3. Customer Identification (KYC)

Depending on product tier and jurisdiction, we may require identity verification before enabling deposits, withdrawals, or higher limits. Typical data includes:

• Full legal name, date of birth, and residential address.
• Government-issued photo ID (passport, national ID, or driver’s license).
• Proof of address (utility bill, bank statement) when required.
• Selfie / liveness check to match the ID document.
• For entities: incorporation docs, beneficial ownership (UBO) details, and authorized signatory ID.

4. Ongoing Monitoring

We may monitor account activity for unusual patterns, including rapid in-and-out flows, structuring below thresholds, or inconsistent behavior versus declared profile.

Alerts may result in temporary holds, requests for information, or referral to compliance review.

5. Sanctions & PEP Screening

Users and, where applicable, related parties may be screened against sanctions lists (including OFAC, UN, EU, and UK lists) and politically exposed person (PEP) databases.

Matches are reviewed. Confirmed sanctioned parties are blocked. False positives are cleared through documented review.

6. Source of Funds & Wealth

For elevated risk or large withdrawals, we may ask for source-of-funds / source-of-wealth evidence (e.g., employment income, business proceeds, investment statements).

Failure to provide satisfactory information may result in restricted functionality or account closure.

7. Suspicious Activity Reporting

Where required by law, we will file suspicious activity reports with competent authorities and will not tip off subjects of such reports.

We cooperate with lawful information requests from regulators and law enforcement, subject to applicable legal process.

8. Record Retention

KYC records, screening results, and relevant transaction logs are retained for periods required by applicable AML laws (commonly five years or longer after relationship end), then securely deleted or anonymized where permitted.

9. Prohibited Users & Activities

We do not knowingly onboard or serve:

• Persons or entities on applicable sanctions lists.
• Shell companies without transparent ownership where required.
• Users seeking to layer illicit proceeds through prediction markets.
• Activity involving darknet markets, ransomware proceeds, or similar high-risk typologies.

10. Your Obligations

You must provide truthful information, keep KYC documents current, and not allow third parties to trade through your account.

You must not use the Platform to conceal the origin of funds or to evade sanctions or AML controls.

11. Limits & Freezes

We may impose deposit, trade, or withdrawal limits; freeze assets; or exit relationships where risk cannot be mitigated, in accordance with law and this Policy.

12. Contact — Compliance

Compliance inquiries: [email protected] (placeholder). For urgent account freezes related to suspected unauthorized access, contact support through the in-app channel first.