AML/CFT and KYC Policy

Eyeknown is committed to maintaining a robust compliance framework to prevent money laundering, terrorist financing, sanctions evasion, fraud, and other illicit activity. This Policy summarizes our anti‑money laundering and counter‑terrorist financing (AML/CFT) and know‑your‑customer/business (KYC/KYB) standards.

1) Governance and Responsibility

• Board‑level oversight of AML/CFT compliance.
• Designation of a Compliance Officer/MLRO with day‑to‑day responsibility.
• Independent testing and periodic audits of the program.

2) Risk‑Based Approach

We apply a risk‑based approach considering customer type, geography, products/services, delivery channels, transaction behavior, and counterparties. Controls scale with risk, including enhanced due diligence (EDD) where appropriate.

3) Customer Due Diligence (CDD/KYC and KYB)

• Individuals: collection and verification of identity (government ID, liveness where applicable), proof of address, and screening against sanctions/PEP/adverse media.
• Businesses: verification of legal existence, ownership and control (UBOs), directors, nature of business, and verification of authorized signatories; screening of entities and principals.
• Source of Funds/Wealth: obtained where risk dictates, with corroborating evidence for higher‑risk cases.
• Ongoing Monitoring: periodic reviews and event‑driven refresh based on risk.

4) Sanctions, PEP, and Adverse Media Screening

We conduct screening at onboarding and on an ongoing basis against applicable sanctions lists (e.g., OFAC, EU, UN, UK), PEP databases, and adverse media sources. Hits are reviewed and escalated per procedure.

5) Transaction Monitoring and Investigations

We monitor transactions on a risk basis and use rule‑based and behavioral scenarios. Alerts are investigated, and appropriate actions are taken, including requesting information, restricting activity, or filing reports.

6) Advanced Screening

We leverage screening technologies and data sources to assess exposure to illicit activity and support investigations.

7) Recordkeeping

We maintain records of KYC/KYB, screening results, transactions, investigations, and reports for the periods required by applicable regulations.

8) Reporting and Cooperation

We file required suspicious activity/transaction reports and respond to lawful requests from regulators and law enforcement, consistent with confidentiality and data protection requirements.

9) Training and Awareness

Personnel receive role‑appropriate AML/CFT training at onboarding and periodically thereafter, with targeted sessions for higher‑risk functions.

10) Third‑Party and Partner Risk

We conduct due diligence on critical vendors, payment partners, liquidity providers, and custodians, including AML/CFT controls and sanctions compliance.

11) Prohibited and Restricted Activities

We prohibit use of the Services for illicit purposes, including sanctions evasion, fraud, market abuse, ransomware, and activity associated with high‑risk jurisdictions or sectors as defined by policy. We may restrict products or features based on risk.

12) Contact

For AML/KYC inquiries, contact the Compliance team at info@eyeknown.com.