AML & KYC Policy

Compliance Commitment

TSWHZC is committed to maintaining the highest standards of Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance as required by U.S. federal regulations and our FinCEN MSB registration.

Effective Date: To be determined upon platform launch

1. Anti-Money Laundering (AML) Policy

1.1 AML Program Overview

TSWHZC has established a comprehensive AML program designed to detect and prevent money laundering activities, in compliance with the Bank Secrecy Act (BSA), USA PATRIOT Act, and FinCEN requirements. Our program includes:

Transaction Monitoring

Real-time monitoring of all transactions for suspicious patterns and activities using advanced analytics and machine learning.

Suspicious Activity Reporting

Mandatory reporting of suspicious activities to FinCEN through Suspicious Activity Reports (SARs) when required.

Record Keeping

Comprehensive maintenance of customer records and transaction data as required by federal regulations.

Staff Training

Regular training programs for all employees on AML requirements, suspicious activity identification, and reporting procedures.

1.2 Customer Due Diligence (CDD)

We implement risk-based Customer Due Diligence procedures that include:

Verification of customer identity using reliable, independent source documents
Understanding the nature and purpose of customer relationships
Conducting ongoing monitoring of customer accounts and transactions
Enhanced due diligence for high-risk customers and jurisdictions

2. Know Your Customer (KYC) Policy

2.1 KYC Requirements

All users must complete our KYC verification process before accessing platform services. This process is designed to verify customer identity and assess risk levels in accordance with regulatory requirements.

Required Documentation

Identity Verification:

• Government-issued photo ID (passport, driver's license)
• Social Security Number (for U.S. residents)
• Date of birth and full legal name

Address Verification:

• Utility bill or bank statement
• Government correspondence
• Lease agreement or mortgage statement

2.2 KYC Verification Levels

Level 1 - Basic Verification

Basic identity verification for limited platform access.

• Email and phone verification
• Basic personal information
• Limited trading capabilities

Level 2 - Standard Verification

Full identity and address verification for standard platform features.

• Government ID verification
• Proof of address documentation
• Standard trading and withdrawal limits

Level 3 - Enhanced Verification

Enhanced due diligence for high-value accounts and institutional users.

• Source of funds documentation
• Enhanced background checks
• Higher trading and withdrawal limits

3. Prohibited Activities and Sanctions Compliance

3.1 Prohibited Users and Jurisdictions

TSWHZC prohibits access to users from sanctioned jurisdictions and maintains compliance with OFAC sanctions programs. We screen all users against:

OFAC Specially Designated Nationals (SDN) list
Other U.S. government sanctions lists
International sanctions databases
Politically Exposed Persons (PEP) lists

3.2 Prohibited Activities

The following activities are strictly prohibited on our platform:

Money laundering or terrorist financing
Structuring transactions to avoid reporting requirements
Using the platform for illegal activities
Circumventing sanctions or export controls
Market manipulation or fraudulent trading
Using stolen or fraudulent identification documents

4. Transaction Monitoring and Reporting

4.1 Automated Monitoring Systems

We employ sophisticated transaction monitoring systems that use advanced analytics and machine learning to detect suspicious patterns, including but not limited to:

Unusual Patterns

Transactions inconsistent with customer profile

Structuring

Multiple transactions below reporting thresholds

Geographic Risks

Transactions from high-risk jurisdictions

4.2 Currency Transaction Reports (CTRs)

We file Currency Transaction Reports with FinCEN for cash transactions exceeding $10,000 in a single day, as required by federal law.

5. Record Keeping and Data Retention

TSWHZC maintains comprehensive records of customer information and transactions as required by law, including:

Customer identification and verification records
Transaction records and supporting documentation
Correspondence and communications
Suspicious activity reports and investigations
AML training records and policy documentation

Records are retained for the minimum periods required by law, typically five years from account closure or last transaction date.

6. Compliance Officer and Governance

TSWHZC has designated a qualified AML Compliance Officer responsible for overseeing our AML/KYC program, ensuring regulatory compliance, and serving as the primary contact with regulatory authorities.

7. Policy Updates and Training

This policy is regularly reviewed and updated to reflect changes in regulations and best practices. All employees receive regular AML/KYC training, and the effectiveness of our program is subject to regular independent audits.

Contact: For questions about our AML/KYC policies or to report suspicious activities, please contact our Compliance team through our official contact channels.