AML/KYC Policy

1. Introduction and Commitment

CoinShares AI ("Company," "we," "us," or "our") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This AML/KYC Policy outlines our procedures for preventing, detecting, and reporting money laundering, terrorist financing, and other financial crimes.

We maintain a comprehensive compliance program designed to meet or exceed all applicable regulatory requirements and international standards, including recommendations from the Financial Action Task Force (FATF).

2. Policy Objectives

This AML/KYC Policy is designed to:

• Prevent CoinShares AI from being used for money laundering or terrorist financing
• Ensure compliance with all applicable AML/CTF laws and regulations
• Establish robust customer identification and verification procedures
• Implement effective transaction monitoring and suspicious activity reporting
• Maintain comprehensive records for regulatory and audit purposes
• Protect the integrity of our Platform and the broader financial system
• Foster a culture of compliance throughout our organization

3. Know Your Customer (KYC) Requirements

3.1 Customer Identification Program (CIP)

Before accessing full platform features and Live Mode trading, all customers must complete our identity verification process. We collect and verify:

• Personal Information: Full legal name, date of birth, nationality, residential address
• Contact Information: Email address, phone number
• Government-Issued ID: Valid passport, national identity card, or driver's license
• Proof of Address: Utility bill, bank statement, or government document (dated within 3 months)
• Selfie Verification: Live selfie or video verification to match against identity documents

3.2 Verification Levels

3.3 Document Requirements

Accepted identity documents must be:

• Currently valid (not expired)
• Government-issued with photo
• Clear, legible, and unaltered
• Full color copies (not black and white)
• Showing all four corners visible

Accepted proof of address documents:

• Bank or financial institution statement
• Utility bill (electricity, gas, water, internet)
• Government-issued correspondence
• Tax document or assessment
• Documents must be dated within the last 3 months

4. Customer Due Diligence (CDD)

4.1 Standard Due Diligence

For all customers, we perform:

• Identity verification through document verification services
• Sanctions screening against international watchlists (OFAC, UN, EU, etc.)
• Politically Exposed Person (PEP) screening
• Adverse media screening
• Assessment of customer risk profile

4.2 Enhanced Due Diligence (EDD)

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

• Politically Exposed Persons (PEPs) and their associates
• Customers from high-risk jurisdictions
• Customers with complex ownership structures
• Customers engaging in unusually large or complex transactions
• Customers flagged through transaction monitoring

EDD measures may include:

• Source of funds and source of wealth documentation
• Additional background checks
• Senior management approval for onboarding
• More frequent account reviews
• Lower transaction thresholds for monitoring

4.3 Ongoing Monitoring

Customer due diligence is not a one-time process. We continuously monitor:

• Transaction patterns and account activity
• Changes in customer risk profile
• Updates to sanctions lists and PEP databases
• Adverse media mentions
• Account information accuracy and currency

5. Transaction Monitoring

5.1 Monitoring Systems

We employ sophisticated transaction monitoring systems that analyze:

• Transaction amounts and frequency
• Geographic patterns and IP addresses
• Deposit and withdrawal patterns
• Unusual trading behavior
• Connections between accounts
• Cryptocurrency wallet risk scoring

5.2 Red Flags

Our systems are designed to detect suspicious activities, including:

• Transactions inconsistent with customer profile or stated purpose
• Unusual transaction patterns (structuring, layering)
• Transactions involving high-risk jurisdictions
• Rapid movement of funds through accounts
• Use of multiple wallets or exchanges without clear purpose
• Reluctance to provide required information
• Connections to known illicit wallets or mixers
• Sudden changes in transaction behavior

5.3 Blockchain Analytics

We utilize blockchain analytics tools to:

• Screen cryptocurrency addresses for connections to illicit activity
• Monitor transaction flows across blockchains
• Identify high-risk wallet addresses and services
• Detect connections to darknet markets, mixers, or ransomware

6. Suspicious Activity Reporting

When suspicious activity is identified, our compliance team:

• Investigates and documents the suspicious activity
• Files Suspicious Activity Reports (SARs) with relevant authorities as required
• May freeze or restrict the account pending investigation
• Cooperates with law enforcement inquiries
• Maintains confidentiality of the reporting process

7. Prohibited Activities and Restricted Persons

7.1 Prohibited Activities

The following activities are strictly prohibited on our Platform:

• Money laundering or attempted money laundering
• Terrorist financing
• Fraud or misrepresentation
• Market manipulation
• Using the Platform for illegal purposes
• Structuring transactions to avoid reporting thresholds
• Processing third-party funds without authorization
• Using mixers, tumblers, or privacy coins to obscure transaction origins

7.2 Restricted Persons

We do not provide services to:

• Individuals or entities on international sanctions lists
• Residents of sanctioned or high-risk jurisdictions
• Shell banks or anonymous accounts
• Persons who fail to complete required verification
• Individuals who provide false or misleading information
• Accounts previously terminated for compliance violations

7.3 High-Risk Jurisdictions

We apply enhanced scrutiny or may restrict services for customers from jurisdictions identified as high-risk by:

• FATF (Financial Action Task Force)
• OFAC (Office of Foreign Assets Control)
• EU AML directives
• Other relevant regulatory bodies

8. Record Keeping

We maintain comprehensive records in accordance with regulatory requirements:

• Customer Records: Identity documents, verification records, and account information retained for at least 5 years after account closure
• Transaction Records: All deposits, withdrawals, and trading activity retained for at least 5 years
• Communication Records: Support tickets and compliance-related communications
• Suspicious Activity Records: Investigation files and SAR documentation as required by law

Records are stored securely and made available to regulatory authorities upon lawful request.

9. Staff Training and Awareness

All CoinShares AI personnel receive regular AML/CTF training covering:

• Applicable AML/CTF laws and regulations
• Customer identification and verification procedures
• Recognition of suspicious activity indicators
• Internal reporting procedures
• Record-keeping requirements
• Consequences of non-compliance

Training is provided upon onboarding and updated annually or when significant regulatory changes occur.

10. Compliance Officer

Our designated Compliance Officer is responsible for:

• Overall implementation and enforcement of this AML/KYC Policy
• Reviewing and updating policies and procedures
• Supervising transaction monitoring and suspicious activity investigations
• Filing regulatory reports
• Liaising with regulatory authorities and law enforcement
• Overseeing staff training programs
• Conducting periodic compliance audits

11. Policy Review and Updates

This AML/KYC Policy is reviewed and updated:

• At least annually
• When significant regulatory changes occur
• Following significant compliance incidents
• When new money laundering risks or typologies are identified

Material changes will be communicated to customers through platform notifications and email.

12. Customer Cooperation

By using our Platform, you agree to:

• Provide accurate and complete information during registration and verification
• Promptly update your information when changes occur
• Respond to requests for additional information or documentation
• Not engage in any prohibited activities
• Report any suspicious activity you become aware of

13. Contact Information

For questions about this AML/KYC Policy or our verification requirements: