1. KYC/AML Framework
CRYPTD.TO ("Company") maintains comprehensive Know Your Customer (KYC), Anti-Money Laundering (AML), and Counter-Terrorist Financing (CTF) policies to comply with international regulatory standards, including FATF Recommendations, OFAC regulations, and applicable jurisdictional requirements. This policy applies to all resellers, partners, and customers.
2. Reseller KYC Requirements
Prior to commencing operations, Resellers must provide:
- Complete legal entity information and business registration documentation
- Beneficial ownership disclosure (individuals owning 25% or greater interest)
- Government-issued identification for all beneficial owners
- Proof of business address and operational location
- AML/KYC compliance policies and procedures
- Authorization to conduct cryptocurrency operations in relevant jurisdictions
The Company reserves the right to conduct enhanced due diligence on high-risk resellers based on jurisdiction, customer profile, or transaction characteristics.
3. Customer KYC Obligations for Resellers
Resellers must implement customer KYC procedures for all end-users, including:
- Verification of customer identity using government-issued identification
- Confirmation of customer's full legal name, date of birth, and residential address
- Assessment of source of funds and beneficial ownership (if applicable)
- Risk assessment based on customer profile and transaction patterns
- Ongoing monitoring for suspicious activity and behavioral changes
4. Prohibited Customers and Transactions
Resellers shall not facilitate transactions with:
- Individuals or entities on OFAC Specially Designated Nationals (SDN) list
- Persons or entities in high-risk jurisdictions listed by FATF or other regulatory bodies
- Politically exposed persons (PEPs) without enhanced due diligence
- Customers engaged in illegal activities or money laundering
- Customers with unclear or suspicious source of funds
- Customers who fail to provide required KYC documentation
5. AML Monitoring and Reporting
Resellers agree to:
- Monitor customer transactions for patterns indicative of money laundering
- Document suspicious activity and maintain suspicious activity reports (SARs)
- Report suspected money laundering or terrorist financing to appropriate authorities within required timeframes
- Not disclose to customers that reports have been filed (except as required by law)
- Cooperate with law enforcement investigations
- Maintain audit trails and records of all AML/KYC decisions
6. Risk Assessment and Categorization
Resellers shall implement risk-based KYC procedures that allocate due diligence intensity based on customer risk profiles:
- Low-risk customers may be subject to standard KYC
- Medium-risk customers may require additional documentation and monitoring
- High-risk customers may require enhanced due diligence or rejection
Risk factors include transaction size, customer jurisdiction, industry sector, and transaction patterns.
7. Record Retention and Audit
Resellers shall maintain all KYC documentation, verification records, and AML monitoring files for a minimum of five (5) years. The Company reserves the right to audit Reseller compliance with this policy at any time.
8. Beneficial Ownership Verification
For corporate customers, Resellers must verify the beneficial owners of entities (individuals owning 25% or greater interest). Documentation may include corporate registry extracts, ownership certificates, or third-party verification services.
9. Materially High-Risk Jurisdictions
Customers from jurisdictions identified by FATF as having serious deficiencies in AML/KYC compliance may be subject to enhanced due diligence or rejection. This assessment is updated periodically based on FATF updates and regulatory guidance.
10. Training and Compliance
Resellers must ensure that all personnel involved in customer onboarding and transaction monitoring are trained in AML/KYC procedures and regulations. Training shall be documented and updated annually.
11. Non-Compliance and Sanctions
Resellers who fail to comply with this policy or engage in suspected money laundering, terrorist financing, or sanctions evasion may face:
- Immediate account suspension or termination
- Reporting to regulatory authorities and law enforcement
- Legal action and civil liability
- Forfeiture of compensation and transaction proceeds
12. Governing Jurisdiction
This policy is governed by the laws of the Republic of Seychelles and complies with international standards promulgated by the Financial Action Task Force (FATF) and applicable regulatory agencies.
