1. Purpose and scope
The platform is custodial: we hold client assets and execute payments in and out. That makes us a point at which criminal proceeds could be placed or moved, and this policy exists to make that difficult, detectable and reportable. It applies to every client, every member of staff and every payment rail we operate.
2. Client identification
We verify identity before an account can invest or withdraw. That means a government-issued identity document, a proof of address, and confirmation that the person presenting them is the person in them. Verification is reviewed by a member of staff rather than accepted automatically, and a discrepancy between a declared country and the country in the documents is escalated instead of ignored.
3. Source of funds
Above published thresholds, and at any time when activity does not match what we know about a client, we ask where the money came from and expect documentary evidence — a payslip, a sale contract, a tax return, an exchange statement. An account may be restricted until the answer is satisfactory. We would rather delay a payment than process an unexplained one.
4. Sanctions and PEP screening
Clients are screened against applicable sanctions lists and for politically exposed status at onboarding and on an ongoing basis. A positive match stops the account and is reviewed by a person; a confirmed sanctions match is reported and the relationship ends. We do not operate in jurisdictions we are prohibited from serving, and we do not help anyone appear to be somewhere they are not.
5. Payment rules
Fiat payments must come from an account in the client’s own name at a regulated institution. Third-party payments are returned to source. Payouts go back to an account in the client’s name. Crypto deposits are attributed to the address we issued to that client, and payouts to addresses the client has confirmed under a fresh two-factor challenge.
6. Monitoring and escalation
Deposits, conversions and withdrawals are monitored against velocity, size and pattern rules. A flagged event creates a case for a compliance reviewer with the underlying ledger entries attached. Reviewers can restrict an account, hold a payout for review or request further information; each action is recorded with its reason and its author.
7. Records and reporting
We keep identification records, transaction records and the reasoning behind compliance decisions for the statutory retention period, and the ledger itself is append-only. Where we are required to file a suspicious activity report we do so, and the law generally forbids us from telling the client that we have. We will not invent a different reason to explain a delay, and we will not confirm or deny a filing.
8. Current status
The operating entity and its licences are being established. Until that is complete, fiat rails run in sandbox and no client money moves through them. This policy is published now because the controls it describes are already implemented in the product, not because they will be added later.