AML/KYC Policy

1. Our Commitment

WalletApp is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. We maintain a robust compliance program designed to detect, prevent, and report suspicious activity in accordance with applicable laws and regulations.

2. Know Your Customer (KYC) Requirements

All users must complete identity verification before accessing full platform features. KYC verification requires:

• Tier 1 (Basic): Full name, date of birth, and email address.
• Tier 2 (Standard): Government-issued photo ID (passport, national ID, or driver's license).
• Tier 3 (Enhanced): Proof of address (utility bill or bank statement dated within 3 months) for high-value transactions.

3. Transaction Monitoring

We continuously monitor transactions for suspicious patterns, including but not limited to: unusually large transactions, rapid movement of funds, transactions inconsistent with a user's profile, and patterns indicative of structuring. Suspicious transactions are reviewed by our compliance team and reported to relevant authorities as required by law.

4. Enhanced Due Diligence (EDD)

We apply Enhanced Due Diligence to higher-risk customers, including Politically Exposed Persons (PEPs), users from high-risk jurisdictions, and users whose transaction patterns warrant additional scrutiny. EDD may require additional documentation and source-of-funds declarations.

5. Prohibited Jurisdictions

WalletApp does not provide services to users located in jurisdictions subject to comprehensive sanctions programs or where our services are prohibited by local law. We screen all users against international sanctions lists including OFAC, EU, and UN sanctions lists.

6. Record Keeping

We maintain records of all KYC documentation and transaction history for a minimum of 5 years from the date of account closure, or longer where required by applicable law. All records are stored securely and accessible to authorized compliance personnel and regulators.

7. Reporting Obligations

WalletApp files Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) as required by applicable law. We cooperate fully with law enforcement and regulatory investigations. We are prohibited by law from disclosing to customers that a SAR has been filed.

8. Employee Training

All WalletApp employees receive regular AML/KYC training and are required to report any suspicious activity to our designated compliance officer. Our compliance program is reviewed and updated annually.

9. Contact Compliance

To report suspicious activity or for compliance-related inquiries, contact our Compliance Officer at: [email protected]