Anti-Money Laundering (AML) Policy

Policy Overview

ChainFlow is committed to maintaining the highest standards of anti-money laundering (AML) and counter-terrorism financing (CTF) compliance. We have implemented robust procedures to detect, prevent, and report suspicious activities.

Know Your Customer (KYC) Requirements

We implement comprehensive KYC procedures including:

• Identity verification for all users
• Address verification
• Source of funds documentation
• Enhanced due diligence for high-risk customers
• Ongoing monitoring of customer activities

Customer Due Diligence (CDD)

Transaction Monitoring

We employ automated systems and manual reviews to monitor:

• Large or unusual transactions
• Rapid movement of funds
• Transactions involving high-risk jurisdictions
• Structured transactions designed to avoid reporting thresholds
• Transactions inconsistent with customer profile

Suspicious Activity Reporting

We file Suspicious Activity Reports (SARs) with relevant authorities when we detect transactions or activities that may indicate:

• Money laundering
• Terrorist financing
• Tax evasion
• Fraud
• Other illegal activities

Sanctions Screening

We screen all customers and transactions against:

• OFAC Sanctions Lists
• UN Security Council Sanctions Lists
• EU Sanctions Lists
• Other relevant sanctions and watch lists

Record Keeping

We maintain comprehensive records including:

• Customer identification documents
• Transaction records
• Correspondence with customers
• Risk assessments
• Training records

Records are retained for a minimum of 5 years as required by applicable laws.

Training and Awareness

All employees receive regular AML training covering:

• Recognition of suspicious activities
• Reporting procedures
• Regulatory requirements
• Customer due diligence procedures
• Sanctions compliance

Compliance Officer

Our designated AML Compliance Officer is responsible for:

• Overseeing AML compliance program
• Filing required reports
• Ensuring staff training
• Maintaining relationships with regulatory authorities
• Regular program reviews and updates

Customer Responsibilities

Customers are required to:

• Provide accurate and complete information
• Update information when circumstances change
• Comply with verification requests
• Report any unauthorized account activity
• Ensure compliance with applicable laws in their jurisdiction