AML & KYC Policy

Information Collected for Verification

• Full Legal Name: As it appears on government-issued identification documents

• Date of Birth: To confirm identity and perform age verification

• Residential Address: Current physical address for identity confirmation and regulatory compliance

• Government-Issued ID:Passport, driver's license, national ID card, or other government-issued photo identification

• Employer Identification Number (EIN): For business entities using our formation and financial services

Automated Verification Technology

We utilize Didit as our identity verification provider for automated biometric checks and sanctions screening:

• Biometric Liveness Checks: Didit performs real-time biometric liveness detection to confirm the person presenting the ID is physically present and not using a photo, video, or mask

• Document Authentication: Government-issued IDs are scanned and verified for authenticity, checking for tampering, forgery, and expiration

• OFAC Sanctions Screening: All customers are automatically screened against the OFAC SDN list and other global sanctions databases to ensure compliance with U.S. sanctions law

• Global AML Screening: Didit performs comprehensive AML screening against global watchlists, Politically Exposed Persons (PEP) databases, and adverse media sources

Transaction Monitoring via Stripe

We monitor transactions processed through Stripe, our payment and embedded finance partner, to detect patterns indicative of:

• Money Laundering:Unusual transaction patterns, structuring, rapid movement of funds, and transactions inconsistent with the customer's known business profile

• Terrorist Financing: Transactions involving sanctioned individuals, entities, or jurisdictions, and patterns associated with terrorism funding

• Fraud: Identity theft, account takeover, unauthorized transactions, and synthetic identity fraud

• Sanctions Evasion: Attempts to circumvent U.S. sanctions through indirect transactions or the use of intermediaries

Reporting Obligations

When suspicious activity is identified, we take the following actions:

• File Suspicious Activity Reports (SARs) with FinCEN as required by law

• Freeze or restrict account access pending investigation

• Cooperate fully with law enforcement agencies and regulatory authorities

• Terminate accounts and relationships where warranted

• Maintain records of all reports and investigations for the legally required retention period

Standard Due Diligence

• Verification of customer identity using government-issued documents

• Confirmation of business legitimacy and purpose

• Assessment of the nature and purpose of the business relationship

• Identification and verification of beneficial owners holding 25% or more equity

Enhanced Due Diligence

Enhanced due diligence is applied to customers presenting higher risk factors, including:

• Politically Exposed Persons (PEPs) and their family members or close associates

• Customers from high-risk jurisdictions as identified by FATF or OFAC

• Complex business structures with multiple layers of ownership

• Transactions that are unusually large or inconsistent with the customer's profile