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AML / CTF Policy

Last Updated: 12th April 2026

1. Purpose and Scope

CRYPTD LLC is committed to maintaining a robust Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance program. This policy outlines CRYPTD LLC's approach to identifying, preventing, and mitigating risks associated with money laundering, terrorist financing, and other financial crimes in connection with its cryptocurrency voucher services.

This policy applies to all Company employees, contractors, and third-party service providers involved in the operation of CRYPTD LLC's platform. It supervises the handling of transactions, user interactions (where applicable), and internal processes to ensure compliance with applicable laws and international standards.

2. Business Model Overview

CRYPTD LLC operates as a digital product provider offering cryptocurrencydenominated vouchers. Customers purchase vouchers through authorized channels and redeem them on CRYPTD LLC's platform, resulting in the transfer of cryptocurrency to user-specified wallet addresses. CRYPTD LLC does not operate as an exchange, brokerage, or custodial wallet service.

CRYPTD LLC's AML/CTF program is designed to be proportionate to its business model, focusing on transaction-based risks while maintaining operational efficiency and customer experience.

3. Risk-Based Compliance Approach

CRYPTD LLC employs a risk-based approach to AML/CTF compliance, assessing and mitigating risks based on factors including transaction size, available transaction data, geographic location, and transaction patterns. This approach allows for efficient allocation of compliance resources while ensuring adequate controls for higher-risk activities.

Risk assessments are conducted regularly and inform the design of internal controls, monitoring systems, and review procedures. CRYPTD LLC maintains the ability to apply enhanced scrutiny to transactions or activity identified as higher risk.

4. Customer and Transaction Review

All voucher redemptions are subject to review processes, including manual review and, where applicable, rule-based controls designed to identify potential AML/CTF risks.

CRYPTD LLC reviews transactions for:

  • Unusual transaction patterns or volumes
  • Connections to high-risk jurisdictions or individuals
  • Indications of structuring or layering
  • Inconsistencies with available user-provided information (where applicable)
  • Potential sanctions-related concerns

CRYPTD LLC reserves the right to request additional information from customers or delay, restrict, or cancel transactions where compliance concerns arise.

5. Sanctions and Prohibited Activity Screening

CRYPTD LLC maintains controls designed to prevent transactions involving sanctioned jurisdictions and prohibited activities. These controls include geographic restrictions, transaction monitoring, and risk-based review of activity patterns.

Where sufficient information is available, additional screening measures may be applied against relevant sanctions lists, including those maintained by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and equivalent international lists.

Transactions identified as potentially high-risk or inconsistent with expected behaviour are subject to enhanced review and may be declined or restricted. CRYPTD LLC prohibits the use of its services for sanctions evasion or other prohibited activities.

6. Enhanced Review Measures

For transactions or activity identified as higher risk, CRYPTD LLC may implement enhanced review measures, including:

  • Manual transaction review by compliance personnel
  • Requests for additional information where necessary and proportionate to the transaction risk
  • Consultation with external compliance experts
  • Temporary holds on transaction processing
  • Referral to appropriate authorities where required by applicable law or deemed appropriate based on the circumstances

Enhanced measures are applied proportionately based on the identified risk level and are designed to balance compliance requirements with operational efficiency.

7. Transaction Monitoring and Risk Indicators

CRYPTD LLC maintains ongoing transaction monitoring processes, including manual review and rule-based controls, to identify suspicious activity patterns. Key risk indicators include:

  • Rapid succession of high-value transactions
  • Transactions involving multiple jurisdictions
  • Unusual redemption patterns inconsistent with observed transaction behavior
  • Attempts to circumvent monitoring controls
  • Connections to known high-risk activities

Identified suspicious activities are documented and may trigger internal escalation procedures or external reporting as appropriate.

8. Internal Controls and Escalation

CRYPTD LLC maintains internal controls to ensure consistent application of AML/CTF policies, including:

  • Clear escalation procedures for compliance concerns
  • Secondary review of high-risk decisions where appropriate based on the level of risk
  • Periodic internal review of compliance processes

Compliance concerns are escalated through defined channels to ensure timely resolution and appropriate action.

9. Record Retention

CRYPTD LLC maintains records of all transactions, user interactions (where applicable) and compliance decisions for a minimum period of five years, or as required by applicable law. Records are securely stored and accessible for regulatory review or internal audits.

Record retention practices ensure CRYPTD LLC can demonstrate compliance with AML/CTF requirements and support any necessary investigations or regulatory inquiries.

10. Policy Review and Updates

This policy is reviewed annually or more frequently as needed to ensure continued effectiveness and compliance with evolving regulatory requirements. Updates may be made in response to:

  • Changes in applicable laws or regulations
  • Evolution of CRYPTD LLC's business model
  • Emerging risks or compliance challenges
  • Recommendations from regulatory authorities
  • Internal audit findings

All policy updates are documented and communicated to relevant personnel.

11. Cooperation with Lawful Requests

CRYPTD LLC cooperates with lawful requests from regulatory authorities, law enforcement agencies, and other competent bodies. This includes providing information, records, and assistance as required by applicable law.

Cooperation is conducted in accordance with legal requirements and CRYPTD LLC's commitment to maintaining lawful and transparent operations.

12. Governing Standards

This policy is informed by applicable laws and international AML/CTF standards, including Financial Action Task Force (FATF) guidance, where relevant to CRYPTD LLC's business model. CRYPTD LLC strives to maintain compliance with relevant regulatory expectations while operating its business model responsibly.

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