🖋️AML & KYC Policy (OTC Service)

Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy and Procedures for Over The Counter (OTC) service.

Introduction

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy and Procedures document outlines the measures taken by One80 to prevent the use of it’s Over The Counter (OTC) services, for illicit activities, including money laundering, terrorist financing, and other financial crimes. This policy ensures compliance with international AML and KYC regulations and establishes a framework for secure and transparent financial transactions.

This AML and KYC policies and procedures do not affect our other DeFi products, our ecosystem operates in a fully autonomous and non-custodial manner. Our DeFi products are built on smart contracts that execute transactions without intermediaries, ensuring that users always retain full control over their assets. Since we do not hold or manage user funds, our DeFi offerings do not fall under the same regulatory obligations as centralized entities in many jurisdictions . This distinction allows us to implement AML and KYC measures specifically where necessary, while maintaining the permissionless, decentralized nature of our other products.

Regulatory Compliance

One80 adheres to global AML and KYC laws, including but not limited to:

• The Financial Action Task Force (FATF) Recommendations

• The European Union’s Anti-Money Laundering Directives (AMLD)

• The United Nations Office on Drugs and Crime (UNODC) Guidelines

• Local regulatory frameworks in jurisdictions where the company operates

Customer Due Diligence (CDD)

One80 implements a risk-based approach to customer identification and verification to ensure compliance with regulatory standards.

Know Your Customer (KYC) Requirements

Before engaging in transactions, customers must provide the following information:

• Full legal name

• Government-issued identification (passport, driver’s license, national ID, etc.)

• Selfie verification (to match with government ID)

• Email verification

• Telephone verification

• Business registration documents (if applicable, for corporate clients)

• Source of funds declaration (for high-value transactions only)

Enhanced Due Diligence (EDD)

For high-risk customers, additional verification steps are required:

• Enhanced identity verification through multiple document checks

• Source of wealth and funds analysis

• Additional background checks, including adverse media screening

Transaction Monitoring and Reporting

One80 will continuously monitors transactions to detect suspicious activities, including but not limited to:

• Transactions exceeding pre-set thresholds

• Rapid and repetitive transactions just below reporting limits

• Transactions involving high-risk jurisdictions

• Unusual or uncharacteristic transaction patterns

Suspicious Activity Reporting (SAR)

If suspicious activity is detected, the team will investigate and, if necessary, file a Suspicious Activity Report (SAR) with the relevant regulatory authorities in the applicable jurisdiction.

Record-Keeping

Records of transactions, customer identification, and compliance reports will be maintained, as required by applicable laws in different jurisdictions.

Sanctions and Blacklist Screening

One80 screens customers and transactions against international sanctions and watchlists, including but not limited to:

• Office of Foreign Assets Control (OFAC) list

• United Nations Security Council (UNSC) sanctions list

• European Union (EU) and United Kingdom sanctions lists

• Financial Crimes Enforcement Network (FinCEN) watchlist

• Any other applicable global sanctions lists

Procedures for Compliance

Onboarding Process

• Customers must submit required KYC documents before trading.

• Compliance team verify the documents and conduct assessments.

• Accounts are approved or rejected based on the customer’s risk profile.

Ongoing Monitoring

• All transactions are continuously monitored for red flags.

• High-risk accounts are subject to periodic enhanced due diligence reviews.

• Automated and manual checks ensure compliance with AML regulations.

Reporting and Escalation

• Employees must report any suspicious activity to the Compliance Officer.

• If necessary, a SAR is filed with the appropriate regulatory body.

• Records of reports and investigations are securely maintained for audit purposes.

Employee Training and Compliance

Employees undergo periodic AML and KYC training to ensure they understand and implement compliance policies effectively. Training covers:

• Identification of suspicious activities

• Proper customer due diligence procedures

• International AML and KYC regulations

• Internal reporting and escalation processes

Internal Audit and Review

The AML and KYC program undergoes periodic internal audits to ensure:

• Adherence to global regulatory requirements

• Effectiveness of compliance procedures

• Identification and resolution of potential vulnerabilities

• Continuous improvement of AML and KYC measures

Consequences of Non-Compliance

Failure to comply with AML and KYC policies may result in:

• Account suspension or termination

• Reporting to regulatory authorities

• Internal disciplinary actions against responsible employees

Contact Information

For any questions regarding this AML and KYC Policy and Procedures, please contact the One80 team at [e-mail] .