AML & KYC Policy

• Tier 1 (basic wallet): phone verification and self-declared identity — low transaction limits.
• Tier 2 (verified): government-issued ID + selfie liveness check + address confirmation.
• Tier 3 (enhanced): Tier 2 plus source-of-funds evidence, for higher-limit and business users.

Every new user is screened against sanctions lists (UN, OFAC, EU, UK) and Politically-Exposed-Person (PEP) databases at onboarding and then re-screened daily while the account is open.

• Automated rules flag structuring, unusual velocity, high-risk corridors, dormant-then-active accounts and device sharing.
• All alerts are triaged by the compliance team; genuine suspicions are escalated.

Where we form a suspicion of money laundering or terrorism financing, we file a Suspicious Activity Report (SAR) with the Financial Intelligence Unit in the manner and time-frame required by law. We do not tip off the customer.

KYC files, transaction records and SAR working papers are retained for at least 7 years after the account is closed.

• A named Money-Laundering Reporting Officer (MLRO) owns the programme.
• Annual independent AML audit; findings tracked to closure by the board.
• Every staff member completes AML training on hire and annually thereafter.

We do not knowingly facilitate transactions relating to: sanctioned parties, weapons trafficking, human trafficking, child sexual abuse material, unlicensed gambling, wildlife trafficking, or virtual-asset service providers that are not themselves licensed. Accounts found doing so are frozen and reported.