Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

1. Introduction

CryptsCorp, operated by Oscorp Global Center LLC ("Company"), is committed to maintaining the highest standards of compliance with anti-money laundering (AML) and know your customer (KYC) regulations. This policy outlines our procedures for preventing money laundering, terrorist financing, and other illicit activities.

2. Regulatory Compliance

Our AML/KYC program complies with:

• The Bank Secrecy Act (BSA)
• The USA PATRIOT Act
• Financial Crimes Enforcement Network (FinCEN) regulations
• Office of Foreign Assets Control (OFAC) sanctions
• State money transmitter licensing requirements

3. Customer Identification Program (CIP)

Before providing services, we collect and verify the following information:

For Individual Customers:

• Full legal name
• Date of birth
• Physical address (not P.O. Box)
• Government-issued photo identification
• Social Security Number or Tax ID
• Source of funds documentation

For Business Customers:

• Legal business name and any DBAs
• Business registration documents
• Tax identification number
• Physical business address
• Beneficial ownership information
• Authorized representative documentation

4. Enhanced Due Diligence (EDD)

We conduct enhanced due diligence for:

• High-risk customers or jurisdictions
• Politically Exposed Persons (PEPs)
• Customers from OFAC sanctioned countries
• Large transactions exceeding $10,000
• Unusual or suspicious transaction patterns

5. Prohibited Activities

We strictly prohibit the use of our services for:

• Money laundering or terrorist financing
• Fraud, illegal gambling, or other criminal activities
• Transactions involving sanctioned individuals or entities
• Structuring transactions to avoid reporting requirements
• Using stolen or illegally obtained funds
• Circumventing currency controls or regulations

6. Transaction Monitoring

Our automated monitoring systems continuously review transactions for:

• Unusual transaction amounts or frequencies
• Rapid movement of funds
• Transactions inconsistent with customer profiles
• Connections to high-risk addresses or entities
• Potential structuring or layering activities

7. Suspicious Activity Reporting

We file Suspicious Activity Reports (SARs) with FinCEN when we detect:

• Known or suspected criminal activity
• Transactions with no apparent lawful purpose
• Attempts to evade reporting requirements
• Transactions totaling $5,000 or more where identity is unknown

Note: Federal law prohibits us from disclosing SAR filings to customers or third parties.

8. Record Keeping

We maintain comprehensive records including:

• Customer identification and verification documents
• Transaction records and supporting documentation
• AML training records and compliance certificates
• Audit trails and monitoring system logs
• Correspondence with regulatory authorities

Records are retained for a minimum of five (5) years as required by law.

9. OFAC Sanctions Screening

We screen all customers and transactions against:

• OFAC Specially Designated Nationals (SDN) List
• OFAC Consolidated Sanctions List
• Other relevant government watch lists
• Blocked cryptocurrency addresses

Transactions involving sanctioned parties are immediately blocked and reported.

10. Training and Compliance

All employees receive regular AML/KYC training covering:

• Recognition of suspicious activities
• Proper customer identification procedures
• Regulatory requirements and updates
• Escalation and reporting procedures
• Confidentiality and record keeping

11. Customer Obligations

As our customer, you agree to:

• Provide accurate and complete identification information
• Update your information promptly when changes occur
• Respond to our requests for additional documentation
• Use our services only for lawful purposes
• Report any unauthorized access to your account

12. Consequences of Non-Compliance

Failure to comply with our AML/KYC requirements may result in:

• Account suspension or termination
• Transaction blocking or reversal
• Mandatory reporting to authorities
• Legal action and law enforcement referral

13. Contact Information

For AML/KYC related inquiries, contact our Compliance Department:

14. Policy Updates

This policy may be updated periodically to reflect changes in regulations or business practices. The current version is always available on our website. Continued use of our services constitutes acceptance of any policy modifications.

Last Updated: January 1, 2024