Anti-Money Laundering (AML), Know Your Customer (KYC) & Counter-Terrorist Financing (CTF) Policy

1. Purpose

Control Money is committed to maintaining the highest standards of Anti-Money Laundering (“AML”), Counter-Terrorist Financing (“CTF”), Counter-Proliferation Financing (“CPF”), sanctions compliance, and fraud prevention.

This Policy describes the controls adopted by Control Money to:

• prevent misuse of the Platform;
• comply with applicable AML laws and regulations;
• identify and manage financial crime risks;
• protect customers and business partners; and
• support regulatory reporting obligations.

This Policy applies to all users, employees, contractors, and relevant third-party service providers.

2. Scope

This Policy applies to all products and services offered by Control Money, including:

• account onboarding;
• fiat deposits and withdrawals;
• digital asset wallets;
• stablecoin services;
• yield-bearing products;
• tokenized ETFs and stocks;
• transfers;
• customer support interactions.

3. Regulatory Framework

Control Money seeks to comply with all applicable AML, CTF, sanctions, and financial crime laws in the jurisdictions in which it operates, including requirements relating to:

• customer identification;
• beneficial ownership;
• sanctions screening;
• suspicious transaction reporting;
• transaction monitoring;
• record retention;
• regulatory reporting.

Where multiple legal frameworks apply, Control Money will adopt the higher compliance standard where reasonably practicable.

4. Risk-Based Approach

Control Money applies a risk-based approach to customer onboarding and ongoing monitoring.

Risk assessments consider factors including:

• country of residence;
• nationality;
• occupation;
• source of funds;
• source of wealth;
• transaction size and frequency;
• product usage;
• blockchain exposure;
• sanctions risk;
• adverse media;
• politically exposed person (“PEP”) status.

Users may be classified as Low, Medium, High, or Prohibited Risk.

5. Customer Identification (KYC)

All customers must complete identity verification before accessing regulated services.

Verification may include:

• full legal name;
• date of birth;
• residential address;
• email address;
• mobile number;
• PAN;
• Aadhaar (where legally permitted);
• passport or other government-issued identification;
• selfie or liveness verification;
• bank account verification.

Control Money may refuse onboarding where identity cannot be satisfactorily verified.

6. Beneficial Ownership

Where a customer acts on behalf of a legal entity or another individual, Control Money may require information regarding:

• ownership structure;
• ultimate beneficial owners (UBOs);
• directors;
• authorized signatories;
• controlling persons.

Failure to disclose beneficial ownership may result in rejection or suspension.

7. Customer Due Diligence (CDD)

Customer Due Diligence includes:

• identity verification;
• sanctions screening;
• PEP screening;
• adverse media checks;
• address verification where applicable;
• bank account verification;
• ongoing monitoring.

CDD is performed before providing regulated services and periodically thereafter.

8. Enhanced Due Diligence (EDD)

Enhanced Due Diligence may be required for higher-risk customers, including:

• Politically Exposed Persons (PEPs);
• high-net-worth individuals;
• customers from higher-risk jurisdictions;
• unusually large or complex transactions;
• higher-risk business relationships.

EDD measures may include:

• source of funds verification;
• source of wealth verification;
• additional identity documents;
• proof of income;
• video verification;
• enhanced management approval;
• more frequent monitoring.

9. Politically Exposed Persons (PEPs)

Control Money screens customers against recognized PEP databases.

PEP status does not automatically disqualify a customer but may require:

• enhanced due diligence;
• senior compliance approval;
• ongoing monitoring.

10. Sanctions Screening

Control Money screens customers, counterparties, and blockchain wallet addresses against applicable sanctions lists.

Screening is conducted:

• during onboarding;
• before certain transactions;
• periodically during the customer relationship.

Where legally required, Control Money may refuse, suspend, or terminate services.

11. Source of Funds

Control Money may require evidence demonstrating the lawful origin of deposited funds.

Acceptable documentation may include:

• salary statements;
• bank statements;
• tax returns;
• business income records;
• investment proceeds;
• inheritance documentation;
• property sale records.

12. Source of Wealth

Where appropriate, Control Money may request evidence explaining how a customer’s overall wealth was accumulated.

Documentation may include:

• employment records;
• business ownership information;
• audited financial statements;
• investment portfolios;
• inheritance records.

13. Transaction Monitoring

Control Money monitors customer activity using automated systems and manual review.

Monitoring may identify:

• unusual transaction patterns;
• rapid movement of funds;
• structuring or smurfing;
• unusually large transactions;
• high-risk jurisdictions;
• suspicious blockchain activity;
• sanctions exposure;
• fraud indicators.

14. Blockchain Analytics

Control Money may use blockchain analytics tools to assess wallet risk.

Wallets may be screened for associations with:

• sanctioned entities;
• darknet marketplaces;
• ransomware;
• fraud;
• stolen assets;
• mixers or obfuscation services;
• other high-risk activity.

High-risk wallets may be restricted or rejected.

15. Suspicious Activity Reporting

Where required by Applicable Law, Control Money may:

• investigate suspicious activity;
• file Suspicious Transaction Reports (STRs) or equivalent reports;
• cooperate with regulators and law enforcement;
• delay or refuse transactions.

Where prohibited by law, Control Money will not disclose that such reports have been made.

16. Ongoing Monitoring

Customer relationships are reviewed periodically.

Control Money may request updated:

• identification documents;
• address information;
• tax residency;
• source of funds;
• source of wealth;
• employment information.

Failure to respond may result in account restrictions.

17. Record Retention

Control Money retains AML and KYC records for the period required under Applicable Law.

Records may include:

• onboarding documents;
• identification records;
• transaction history;
• compliance reviews;
• sanctions results;
• investigation records;
• regulatory reports.

18. Employee Responsibilities

Employees responsible for AML compliance shall:

• complete periodic AML training;
• escalate suspicious activity;
• protect confidential information;
• comply with internal reporting procedures;
• cooperate with regulators.

19. Third-Party Service Providers

Control Money may engage regulated third parties for:

• identity verification;
• sanctions screening;
• blockchain analytics;
• payment processing;
• custody;
• transaction monitoring.

Control Money remains responsible for oversight of outsourced compliance activities.

20. Policy Updates

This Policy may be amended from time to time to reflect:

• changes in Applicable Law;
• regulatory guidance;
• emerging financial crime risks;
• operational changes;
• improvements to compliance practices.

The latest version will be published on the Platform.

21. Contact

Questions regarding this Policy may be directed to:

Email: compliance@controlmoney.app