Anti-Money Laundering Policy

1. Introduction

SplitNOW is morally opposed to money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines our procedures and measures to ensure compliance with international AML standards and regulations.

2. Legal Framework

This policy is designed based on:

• International AML standards and best practices.
• Financial Action Task Force (FATF) recommendations.

3. Risk Assessment

SplitNOW conducts regular risk assessments to identify and mitigate potential money laundering and terrorist financing risks associated with:

• Customer types and geographic locations.
• Products and services offered.
• Transaction types and volumes.
• Third-party relationships.

4. Customer Due Diligence

4.1 Identity Verification

SplitNOW, despite never requiring KYC (know-your-customer) documentation or identity verification, gauges the customer risk profile based on:

• Source of deposit funds.
• Usage pattern-tracking.
• Suspicious activity patterns.

4.2 Enhanced Due Diligence

Enhanced scrutiny is applied to:

• Politically Exposed Persons (PEPs).
• Customers from high-risk jurisdictions.
• Complex ownership structures.
• Unusual transaction patterns.

5. Transaction Monitoring

We implement automated systems including KYT (know-your-transaction) technologies to monitor transactions for:

• Suspicious activity patterns.
• Transactions involving sanctioned entities.
• Attempts to circumvent monitoring systems.

6. Suspicious Activity Reporting

When suspicious activity is detected, we:

• Conduct internal investigations.
• Implement appropriate risk mitigation measures.
• Internally document all findings and actions taken.

7. Sanctions Compliance

SplitNOW does not provide service to sanctioned entities. We maintain comprehensive sanctions screening including:

• OFAC (Office of Foreign Assets Control) sanctions.
• United Nations Security Council sanctions.
• EU and other regional sanctions lists.
• Regular updates and screening of PEP databases.

9. Training and Awareness

All personnel receive regular training on:

• AML policies and procedures.
• Recognition of suspicious activities.
• Regulatory requirements and updates.
• Ethical standards and professional conduct.

10. Third-Party Relationships

When engaging third parties, we ensure:

• Due diligence on third-party AML controls.
• Ongoing monitoring of third-party performance.
• Right to audit third-party AML procedures.
• Re-routing exchanges to another provider if we cannot ensure compliance with a particular third-party policy.

11. Data Protection

Customer information collected for AML purposes is:

• Handled in accordance with our Privacy Policy.
• Protected by appropriate security measures.
• Used solely for AML and compliance purposes.
• Subject to strict confidentiality requirements.

12. Regulatory Cooperation

SplitNOW cooperates fully with regulatory authorities including:

• Monitoring to ensure ongoing adherence with current and future economic sanctions.
• Implementing regulatory recommendations.
• Maintaining open communication channels.

13. Policy Review and Updates

This AML Policy is reviewed annually and updated to:

• Reflect changes in regulations and best practices.
• Incorporate lessons learned from incidents.
• Address emerging risks and threats.
• Ensure continued effectiveness of controls.

14. Non-Compliance Consequences

On a case-by-case basis, violations of this AML Policy may result in:

• Transaction rejection or account suspension.
• Account termination.
• Mandatory refund.

15. Contact Information

For AML-related inquiries or to report suspicious activity, please contact us at compliance@splitnow.io.

16. Commitment to Compliance

SplitNOW is committed to maintaining the highest standards of AML compliance to protect our customers, the financial system, and society from financial crime.