Anti-Money Laundering Policy

2. Scope

This policy applies to all MACH5 employees, contractors, and users of our platform. We require all parties to adhere to these policies and procedures to prevent money laundering activities.

3. Compliance Officer

We have appointed a dedicated AML Compliance Officer responsible for:

• Developing and maintaining AML policies and procedures
• Training employees on AML requirements
• Monitoring transactions and user activity
• Filing suspicious activity reports
• Maintaining records of AML compliance

4. Customer Due Diligence

We implement a risk-based approach to customer due diligence, including:

• Verifying customer identity using reliable documents
• Screening against sanctions and PEP lists
• Assessing customer risk profiles
• Ongoing monitoring of customer activity
• Enhanced due diligence for high-risk customers

5. Transaction Monitoring

Our platform implements automated systems to monitor transactions for:

• Unusual patterns or volumes
• Structured transactions to avoid reporting
• Transactions with high-risk jurisdictions
• Multiple accounts or frequent transfers
• Suspicious blockchain addresses

6. Record Keeping

We maintain comprehensive records of:

• Customer identification documents
• Transaction history
• Due diligence reports
• Suspicious activity reports
• Training records

7. Employee Training

All employees receive regular training on:

• AML laws and regulations
• Customer due diligence procedures
• Red flags and suspicious activities
• Reporting requirements
• Record keeping requirements

8. Reporting

We have established procedures for:

• Internal reporting of suspicious activities
• Filing Suspicious Activity Reports (SARs)
• Reporting to regulatory authorities
• Cooperation with law enforcement

9. Sanctions Compliance

We screen customers and transactions against:

• OFAC sanctions lists
• UN sanctions lists
• EU sanctions lists
• Other applicable sanctions programs

10. Policy Updates

This policy is reviewed and updated regularly to ensure compliance with changing regulations and emerging risks. Updates will be communicated to all relevant parties.

11. Contact

For AML-related inquiries, please contact our Compliance Officer at [email protected].