KYC/AML Policy

1. Purpose

This policy outlines Qwilon's Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures designed to prevent our platform from being used for money laundering, terrorist financing, or other financial crimes.

2. Regulatory Framework

Our KYC/AML program complies with:

• Financial Action Task Force (FATF) Recommendations
• EU Anti-Money Laundering Directives (AMLD5/6)
• UK Money Laundering Regulations 2017
• US Bank Secrecy Act / FinCEN requirements
• Nigeria Money Laundering (Prevention and Prohibition) Act
• Kenya Proceeds of Crime and Anti-Money Laundering Act
• South Africa Financial Intelligence Centre Act

3. Risk-Based Approach

We assess risk based on customer type, transaction patterns, geography, and product usage. Higher-risk situations receive enhanced due diligence.

4. Verification Tiers

4.1 Bronze (Basic)

• Email verification
• Terms acceptance
• Wallet connection
• Limit: $1,000 total investment

4.2 Silver (Standard)

• Government-issued photo ID
• Proof of address (utility bill or bank statement, less than 3 months old)
• Liveness verification (selfie with ID)
• Sanctions screening
• Limit: $10,000 total investment
• Fee: $10

4.3 Gold (Enhanced)

• All Silver requirements plus:
• Source of funds documentation
• Additional supporting documents
• Manual compliance review
• Limit: Unlimited (subject to project caps)
• Fee: $25
• Required for: All asset creators

5. Required Documents

5.1 Individuals

• Valid passport OR national ID card
• Proof of address: utility bill, bank statement, government letter (less than 3 months)
• Live selfie holding ID
• Source of funds declaration (Gold tier)

5.2 Business Entities

• Certificate of incorporation
• Articles of association / bylaws
• Register of shareholders and directors
• ID verification for all directors and shareholders owning more than 25%
• Proof of business address

6. Beneficial Ownership

We identify any individual who owns more than 25% or exercises significant control over business entities. Each beneficial owner undergoes individual verification.

7. Politically Exposed Persons (PEPs)

PEPs include:

• Heads of state, government ministers, parliamentarians
• Senior judiciary and military officials
• Senior executives of state-owned enterprises
• Immediate family members and close associates of the above

PEPs undergo enhanced due diligence including source of wealth verification, senior management approval, and ongoing monitoring.

8. Sanctions Compliance

All users are screened against:

• UN Security Council Sanctions List
• US OFAC SDN List
• EU Consolidated Sanctions List
• UK HM Treasury Sanctions List
• Relevant local sanctions lists

8.1 Prohibited Jurisdictions

We do not provide services to residents of: North Korea, Iran, Cuba, Syria, Crimea, or any FATF-blacklisted jurisdiction.

9. Transaction Monitoring

Our systems monitor for:

• Unusual transaction volume or velocity
• Patterns inconsistent with stated purpose
• Transactions involving high-risk jurisdictions
• Structuring (breaking transactions to avoid thresholds)
• Sudden changes in user behavior

Flagged transactions undergo manual review.

10. Suspicious Activity Reporting

When suspicious activity is detected:

1. Transaction is flagged for review
2. Compliance team investigates (24-48 hours)
3. Decision to file Suspicious Activity Report (SAR) (48-72 hours)
4. SAR filed with relevant authority per local law

Important: We are prohibited from informing users ("tipping off") that a SAR has been filed.

11. Record Keeping

We retain the following records:

• KYC documents: 7 years after relationship ends
• Transaction records: 7 years
• SAR and investigation files: 7 years
• Training records: 5 years

Records are encrypted, access-controlled, and backed up per our Security Procedures.

12. Staff Training

• All Staff: Annual AML basics training
• Front-line: Bi-annual customer due diligence training
• Compliance Team: Quarterly regulatory updates
• Senior Management: Annual AML risk management

13. Customer Responsibilities

By using our platform, you agree to:

• Provide accurate and complete information
• Update information when it changes
• Not use the platform for illegal purposes
• Cooperate with verification requests

14. Consequences of Non-Compliance

• False information: Account termination, potential legal action
• Failed verification: Access denied or restricted
• Suspicious activity: Account freeze, SAR filing
• Sanctions match: Immediate account block

15. Red Flags

15.1 Identity Red Flags

• Reluctance to provide required information
• Inconsistent or conflicting documentation
• Documents that appear altered or forged
• Use of multiple identities

15.2 Transaction Red Flags

• Round-number transactions without clear purpose
• Transactions just below reporting thresholds
• Rapid movement of funds after deposit
• Transactions inconsistent with stated income

15.3 Geographic Red Flags

• Connections to high-risk or sanctioned jurisdictions
• Use of VPNs to mask location
• Frequent access from different countries

16. Cooperation with Authorities

We cooperate with law enforcement by:

• Responding to valid legal requests
• Filing required regulatory reports
• Providing testimony when legally required

We do not voluntarily share data without legal basis.

17. Policy Review

This policy is reviewed:

• At least annually
• When regulations change
• After significant incidents
• When business model changes

18. Contact

Compliance Questions: compliance@qwilon.com
Report Suspicious Activity: security@qwilon.com