AML & KYC Policy

1. Policy Overview

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines IDCXS's commitment to preventing illicit financial activities and ensuring compliance with applicable laws. Our procedures are designed to:

• Prevent money laundering and terrorist financing
• Verify the identity of our customers
• Monitor and report suspicious activities
• Maintain comprehensive records of transactions
• Comply with sanctions and regulatory requirements

2. Know Your Customer (KYC) Requirements

2.1 Customer Identification Program (CIP)

All customers must complete our verification process before accessing platform services. The CIP requires:

2.2 Enhanced Due Diligence (EDD)

Enhanced due diligence may be required for:

• High-risk customers or jurisdictions
• Politically Exposed Persons (PEPs)
• Customers with large transaction volumes
• Unusual or complex transaction patterns
• Customers from sanctions-restricted areas

2.3 Ongoing Monitoring

We continuously monitor customer accounts and transactions to ensure ongoing compliance and detect suspicious activities. This includes regular review of customer profiles and transaction patterns.

3. Anti-Money Laundering (AML) Program

3.1 AML Compliance Officer

IDCXS has designated a qualified AML Compliance Officer responsible for overseeing our AML program, ensuring staff training, and maintaining regulatory compliance. The AML Officer reports directly to senior management and has sufficient authority to implement and enforce AML policies.

3.2 Risk Assessment

We conduct comprehensive risk assessments considering:

• Customer types and geographic locations
• Products and services offered
• Transaction volumes and patterns
• Delivery channels and payment methods
• Regulatory environment changes

3.3 Transaction Monitoring

Our automated monitoring systems analyze transactions in real-time to identify suspicious patterns, unusual activities, and potential violations of AML regulations. Alert parameters are regularly reviewed and updated based on risk assessments.

4. Suspicious Activity Reporting

4.1 SAR Filing Requirements

IDCXS files Suspicious Activity Reports (SARs) with FinCEN when we detect:

• Transactions with no apparent lawful purpose
• Unusual transaction patterns or volumes
• Attempts to avoid reporting requirements
• Transactions involving known criminal activities
• Activities that may indicate terrorist financing

4.2 Internal Reporting

All employees are trained to identify and report suspicious activities to the AML Compliance Officer. We maintain strict confidentiality regarding SAR filings and investigations.

5. Sanctions Compliance

5.1 Sanctions Screening

We screen all customers and transactions against relevant sanctions lists including:

• OFAC Specially Designated Nationals (SDN) list
• UN Security Council sanctions lists
• EU consolidated sanctions list
• Other applicable jurisdiction sanctions

5.2 Prohibited Jurisdictions

IDCXS does not provide services to individuals or entities located in or organized under the laws of certain high-risk or sanctions-restricted jurisdictions. This list is regularly updated based on regulatory guidance.

6. Record Keeping

6.1 Documentation Requirements

We maintain comprehensive records including:

• Customer identification and verification documents
• Transaction records and supporting documentation
• SAR filings and related investigations
• Risk assessments and monitoring reports
• Training records and policy updates

6.2 Retention Periods

Records are retained in accordance with applicable regulations, typically for a minimum of five years after account closure or transaction completion. Some records may be retained longer as required by law or regulatory guidance.

7. Staff Training

All IDCXS employees receive comprehensive AML/KYC training covering:

• Money laundering and terrorist financing typologies
• Red flags and suspicious activity indicators
• Customer identification and verification procedures
• Sanctions compliance requirements
• Reporting obligations and procedures
• Record keeping requirements

8. Independent Testing

IDCXS conducts regular independent testing of our AML program through qualified internal audit or external third parties. Testing evaluates the effectiveness of our policies, procedures, and controls, with findings addressed promptly.

9. Customer Cooperation

10. Contact Information

For questions regarding our AML/KYC procedures or to report suspicious activities: