Anti-Money Laundering Policy

1. Program Overview

DIRE MONEY TRANSMITTER LLC, operating the Cryptiva platform, maintains a written Anti-Money Laundering program as required under 31 U.S.C. § 5318 and implementing regulations at 31 C.F.R. Part 1022. The program is designed to prevent the Cryptiva platform from being used to facilitate money laundering, terrorist financing, or other financial crimes.

The AML program is built around four core pillars: written policies and procedures, a designated compliance officer, ongoing employee training, and independent testing of program effectiveness. These elements are maintained continuously and reviewed regularly.

2. Know Your Customer (KYC) Requirements

No account on the Cryptiva platform may be used for trading or wallet activity without completing identity verification. This requirement applies to all users without exception.

2.1 Identity Verification Requirements

All users must provide the following information at account creation:

• Full legal name as it appears on government-issued identification
• Date of birth
• Residential address (P.O. Box addresses are not accepted as primary address)
• Government-issued photo identification (passport, driver's license, or state ID)
• Social Security Number or Individual Taxpayer Identification Number where required

2.2 Verification Process

Submitted identity documents are reviewed by the Cryptiva compliance team. Accounts remain in a restricted state until verification is complete and approved. Cryptiva reserves the right to request additional documentation if submitted materials are insufficient or inconsistent.

2.3 Beneficial Ownership

For accounts opened by legal entities, information about beneficial owners holding 25% or more of the entity must be provided and verified. This requirement aligns with FinCEN's Customer Due Diligence Rule.

3. Transaction Monitoring

All transactions on the Cryptiva platform are subject to ongoing monitoring. The monitoring program uses both automated screening and manual review to identify activity that may indicate money laundering, terrorist financing, or other financial crime.

3.1 Automated Screening

Transaction amounts, frequencies, and patterns are evaluated against defined thresholds and behavioral models. Transactions that trigger screening alerts are flagged for manual review by the compliance team.

3.2 OFAC Screening

All accounts and transactions are screened against the Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list and other applicable sanctions lists. Accounts or transactions matching sanctioned parties are blocked and reported as required by law.

3.3 Currency Transaction Reports

Currency Transaction Reports (CTRs) are filed with FinCEN for transactions exceeding applicable thresholds as required under 31 C.F.R. § 1022.310. Structuring transactions to avoid CTR filing thresholds is prohibited and may itself trigger a Suspicious Activity Report.

4. Suspicious Activity Reporting

DIRE MONEY TRANSMITTER LLC is required to file Suspicious Activity Reports (SARs) with FinCEN when it knows, suspects, or has reason to suspect that a transaction involves funds from illegal activity, is designed to evade reporting requirements, lacks a lawful purpose, or involves a violation of law that the company is aware of.

4.1 SAR Filing Obligations

SARs are filed for transactions of $2,000 or more that meet the criteria above. The existence of a SAR filing is confidential. Cryptiva is prohibited by law from disclosing to any person that a SAR has been filed with respect to their account or transactions.

4.2 No Tipping Off

When a SAR has been filed or is under consideration, Cryptiva staff are prohibited from disclosing this fact to the subject of the report or any third party. This prohibition is a federal legal requirement under 31 U.S.C. § 5318(g)(2).

5. No Anonymous Transactions

Cryptiva does not permit anonymous transactions under any circumstances. Every transaction on the platform is associated with a verified account. Wallet addresses used on the platform are linked to the identity-verified account holder. There is no mechanism for conducting transactions without a verified identity on file.

6. Prohibited Activities

The following activities are prohibited on the Cryptiva platform:

• Transactions involving proceeds of criminal activity
• Structuring transactions to avoid reporting thresholds
• Providing false identity information during account creation or verification
• Using the platform on behalf of a sanctioned individual or entity
• Attempting to circumvent AML monitoring or KYC requirements
• Operating accounts on behalf of undisclosed third parties

7. Record Keeping

DIRE MONEY TRANSMITTER LLC maintains records of all transactions, identity verification documents, and compliance-related communications as required under 31 C.F.R. Part 1022. Records are retained for a minimum of five years from the date of the transaction or account closure, whichever is later.

8. Employee Training

All personnel with compliance-related responsibilities receive training on AML requirements, red flag indicators, and internal reporting procedures. Training is conducted at onboarding and updated regularly as regulations and platform operations evolve.

9. Independent Testing

The AML program is subject to independent testing to evaluate its effectiveness. Testing results are reviewed by program leadership and any identified deficiencies are addressed in a documented remediation process.

10. Contact for Compliance Questions

Questions about the Cryptiva AML program, account verification requirements, or compliance-related matters may be directed to: