AML & KYC Policy

1.Purpose

TODO (counsel): Operator's commitment to preventing money laundering and terrorist financing.

2.Customer Due Diligence (KYC)

TODO (counsel): When KYC is triggered (e.g., before first redemption, at $X cumulative redeemed, etc.) and what's verified.

3.Enhanced Due Diligence

TODO (counsel): Triggers for EDD: high-value redemptions, source-of-funds, PEPs.

4.Ongoing Monitoring

TODO (counsel): Transaction monitoring, structuring, watchlist screening.

5.Suspicious Activity Reporting

TODO (counsel): SAR filing process, internal escalation chain, regulator contact.

6.Record Keeping

TODO (counsel): Retention period per applicable law (typically 5 years post account closure).

7.Training & Governance

TODO (counsel): Staff training cadence; MLRO appointment if required.

8.Prohibited Customers & Sources

TODO (counsel): Sanctioned jurisdictions, OFAC, prohibited customer types.