Anti-Money Laundering (AML) Policy

CIPHER is committed to preventing money laundering, terrorist financing, fraud, and other illicit activities through its platform and ecosystem.

This Anti-Money Laundering (AML) Policy outlines the framework and procedures adopted by CIPHER to comply with applicable AML, Counter-Terrorist Financing (CTF), and sanctions regulations.

Introduction

CIPHER is committed to preventing money laundering, terrorist financing, fraud, and other illicit activities through its platform and ecosystem. This Anti-Money Laundering (AML) Policy establishes the framework and procedures adopted by CIPHER to comply with applicable AML, Counter-Terrorist Financing (CTF), and sanctions regulations.

Purpose

• Prevent the use of CIPHER for money laundering or terrorist financing activities.
• Detect and report suspicious transactions.
• Ensure compliance with applicable laws and regulatory requirements.
• Protect the integrity of the CIPHER ecosystem and its users.

Customer Due Diligence (CDD)

CIPHER may require users, partners, merchants, or institutions utilizing its services to undergo identity verification procedures.

Verification measures may include:

• Full legal name verification.
• Government-issued identification.
• Proof of address documentation.
• Business registration documents (for corporate entities).
• Source of funds verification where applicable.

Enhanced Due Diligence (EDD) may be applied to higher-risk users or transactions.

Risk-Based Approach

CIPHER applies a risk-based approach to assess and mitigate AML risks.

Risk factors considered include:

• Geographic location.
• Transaction volume and frequency.
• Customer type.
• Source of funds.
• Nature of business activities.

Higher-risk activities may be subject to additional verification and monitoring.

Transaction Monitoring

CIPHER reserves the right to monitor transactions conducted through its ecosystem to identify potentially suspicious activities, including but not limited to:

• Unusual transaction patterns.
• Structuring or smurfing activities.
• Rapid movement of funds.
• Transactions involving sanctioned or high-risk jurisdictions.
• Activities inconsistent with a user's known profile.

Sanctions Compliance

CIPHER prohibits transactions involving:

• Individuals or entities subject to international sanctions.
• Persons listed on applicable sanctions lists.
• Jurisdictions subject to comprehensive sanctions restrictions.

CIPHER may screen users and wallet addresses against sanctions databases and blockchain analytics tools.

Suspicious Activity Reporting

Where required by applicable laws and regulations, CIPHER may report suspicious transactions or activities to competent authorities.

CIPHER reserves the right to:

• Request additional information.
• Delay or suspend transactions.
• Freeze or restrict access to services.
• Terminate accounts associated with suspicious activities.

Record Keeping

CIPHER may maintain records relating to:

• User identification information.
• Verification documents.
• Transaction history.
• Risk assessments.
• Compliance reviews.

Records may be retained for the period required by applicable laws and regulations.

Prohibited Activities

Users are prohibited from using CIPHER for:

• Money laundering.
• Terrorist financing.
• Fraudulent activities.
• Human trafficking.
• Drug trafficking.
• Tax evasion.
• Sanctions evasion.
• Financing illegal activities.
• Any activity prohibited by applicable law.

Compliance Officer

CIPHER may designate a Compliance Officer responsible for:

• AML program oversight.
• Risk management.
• Regulatory compliance.
• Internal investigations.
• Suspicious activity reporting.

Cooperation with Authorities

CIPHER may cooperate with law enforcement agencies, regulators, and competent authorities where legally required or permitted.

Policy Updates

CIPHER reserves the right to amend this AML Policy at any time to reflect changes in legal, regulatory, operational, or business requirements.

Contact Information

For AML compliance inquiries, please contact:

Compliance Department

• Email: compliance@cipher.io
• Website: https://cipher.io