Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), Know Your Customer (KYC) And Client Identification Policy

Effective Date: 1 January 2026

1. Introduction

AEGIS Wallet ("AEGIS", "Company", "we", "our", or "us") is committed to maintaining the highest standards of integrity, transparency, regulatory compliance, and financial crime prevention.

As a digital asset wallet, payment, and financial technology platform, AEGIS recognizes the risks associated with money laundering, terrorist financing, sanctions evasion, fraud, corruption, cybercrime, tax evasion, and other unlawful activities.

The Company strictly prohibits the use of its platform, wallets, services, systems, infrastructure, products, and business relationships for any illegal or unauthorized purpose.

This Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), Know Your Customer (KYC), and Client Identification Policy ("Policy") establishes the principles and procedures adopted by AEGIS to prevent the misuse of its services and to comply with applicable laws, regulations, and international best practices relating to financial crime prevention.

By accessing or using AEGIS Wallet, users acknowledge and agree to comply with this Policy and any applicable legal and regulatory requirements.

2. Regulatory Commitment

AEGIS is committed to maintaining a robust compliance framework aligned with applicable international standards and regulatory guidance, including but not limited to:

  • Financial Action Task Force (FATF) Recommendations;
  • United States Bank Secrecy Act (BSA);
  • USA PATRIOT Act;
  • FinCEN guidance relating to digital assets and virtual asset service providers;
  • Office of Foreign Assets Control (OFAC) sanctions requirements;
  • Applicable economic and trade sanctions regulations;
  • Anti-money laundering and counter-terrorist financing legislation;
  • Industry best practices relating to digital assets and financial technology services.

The Company continuously monitors regulatory developments and reserves the right to amend this Policy to reflect changes in applicable laws, regulations, industry standards, and operational requirements.

3. Risk-Based Compliance Approach

AEGIS adopts a risk-based approach to identifying, assessing, mitigating, and managing financial crime risks.

The Company evaluates multiple risk factors, including:

  • Customer profile and background;
  • Country of residence or incorporation;
  • Source of funds and source of wealth;
  • Nature and purpose of the business relationship;
  • Transaction behavior and patterns;
  • Digital asset exposure;
  • Wallet activity and blockchain interactions;
  • Politically Exposed Person (PEP) status;
  • Beneficial ownership structure;
  • Jurisdictional sanctions exposure;
  • Transaction size, frequency, and complexity.

Customers may be categorized into low-risk, medium-risk, or high-risk classifications. Higher-risk relationships may be subject to enhanced due diligence, additional compliance reviews, and ongoing monitoring.

4. Know Your Customer (KYC) Requirements

AEGIS maintains strict customer identification and verification procedures.

No customer account, wallet, or business relationship will be activated until the Company has satisfactorily completed all required verification procedures.

The Company reserves the right to request additional information or documentation at any time.

Individual Customers

Individual customers may be required to provide:

  • Full legal name;
  • Date of birth;
  • Nationality;
  • Residential address;
  • Contact information;
  • Government-issued identification number;
  • Occupation or employment information;
  • Source of funds and source of wealth information where applicable.

Acceptable identification documents may include:

  • Passport;
  • National Identity Card;
  • Driver's License;
  • Residence Permit; or
  • Other government-issued identification documents accepted by the Company.

The Company may also request proof of residential address, including:

  • Utility bills;
  • Bank statements;
  • Government-issued correspondence;
  • Tax documents; or
  • Other reliable documentation.

Identity Verification Measures

To prevent fraud, impersonation, identity theft, and unauthorized access, AEGIS may utilize:

  • Selfie verification;
  • Facial recognition verification;
  • Liveness detection;
  • Video verification;
  • Device verification;
  • Multi-factor authentication;
  • Biometric verification technologies.

5. Corporate and Institutional Customers

Corporate entities, partnerships, trusts, foundations, investment vehicles, funds, and other legal arrangements may be required to provide:

  • Certificate of Incorporation;
  • Business Registration Certificate;
  • Memorandum and Articles of Association;
  • Shareholder Register;
  • Director Register;
  • Certificate of Good Standing (where applicable);
  • Certificate of Incumbency (where applicable);
  • Organizational Structure Chart;
  • Beneficial Ownership Information;
  • Authorized Signatory Information;
  • Registered Address and Principal Place of Business;
  • Regulatory Licenses;
  • Tax Identification Information;
  • Audited Financial Statements where appropriate.

The Company may request additional information necessary to understand the nature of the entity, ownership structure, source of funds, and intended business activities.

6. Beneficial Ownership Verification

AEGIS shall identify and verify Ultimate Beneficial Owners (UBOs), controlling persons, authorized representatives, and individuals acting on behalf of legal entities.

Where ownership structures are complex, layered, offshore, involve nominee arrangements, trusts, shell entities, or other structures that may obscure beneficial ownership, the Company may request additional documentation and independent verification evidence.

Failure to satisfactorily verify beneficial ownership may result in rejection, suspension, restriction, or termination of the customer relationship.

7. Simplified Due Diligence (SDD)

Where permitted by applicable laws and regulations, AEGIS may apply Simplified Due Diligence measures to customers assessed as presenting lower financial crime risks.

Examples may include:

  • Government agencies;
  • Public authorities;
  • Regulated financial institutions;
  • Publicly listed companies;
  • Other low-risk customers as determined by the Company.

The application of Simplified Due Diligence does not remove the Company's obligation to verify customer identity, conduct sanctions screening, or monitor customer activities.

8. Enhanced Due Diligence (EDD)

Enhanced Due Diligence may be applied where a customer, transaction, jurisdiction, or business relationship presents elevated financial crime risk.

Examples include:

  • Politically Exposed Persons (PEPs);
  • High-net-worth individuals;
  • Customers from high-risk jurisdictions;
  • Customers conducting large or complex digital asset transactions;
  • Customers utilizing privacy-enhancing technologies;
  • Customers with unusual transaction patterns;
  • Customers whose activities are inconsistent with their stated profile.

The Company may require additional information concerning:

  • Source of funds;
  • Source of wealth;
  • Business activities;
  • Investment objectives;
  • Transaction rationale;
  • Wallet ownership;
  • Historical transaction activity.

9. Sanctions Compliance

AEGIS maintains a strict sanctions compliance framework.

The Company screens customers, beneficial owners, counterparties, wallet addresses, and transactions against applicable sanctions lists, including:

  • United States OFAC lists;
  • United Nations sanctions lists;
  • European Union sanctions lists;
  • United Kingdom sanctions lists;
  • Other relevant international sanctions databases.

The Company reserves the right to restrict, suspend, reject, freeze, or terminate accounts, wallets, transactions, or business relationships involving sanctioned persons, entities, jurisdictions, or wallet addresses.

10. Transaction Monitoring

AEGIS maintains ongoing monitoring systems designed to detect suspicious, unusual, fraudulent, or potentially unlawful activities.

Monitoring may include:

  • Transaction pattern analysis;
  • Wallet activity reviews;
  • Blockchain monitoring;
  • Counterparty screening;
  • Automated surveillance systems;
  • Artificial intelligence monitoring tools;
  • Manual compliance reviews.

Activities subject to enhanced review may include:

  • Rapid movement of funds between wallets;
  • Structuring transactions to avoid thresholds;
  • Unusual deposits and withdrawals;
  • High-risk wallet interactions;
  • Darknet marketplace exposure;
  • Use of mixers, tumblers, or anonymization services;
  • Transactions lacking apparent economic purpose;
  • High-risk jurisdiction exposure.

The Company reserves the right to request supporting documentation or conduct additional compliance reviews before processing transactions.

11. Blockchain Analytics and Digital Asset Monitoring

Given the nature of blockchain technology and digital assets, AEGIS may utilize blockchain intelligence providers, wallet screening solutions, transaction monitoring systems, and blockchain analytics technologies.

These tools may assist in:

  • Identifying high-risk wallet addresses;
  • Detecting sanctioned wallets;
  • Monitoring exposure to illicit activities;
  • Identifying fraud and scams;
  • Monitoring ransomware-related activity;
  • Detecting layering and structuring activities;
  • Monitoring darknet marketplace exposure;
  • Assessing wallet risk profiles.

The Company may delay, reject, suspend, restrict, or terminate transactions where elevated compliance risks are identified.

12. Suspicious Activity Reporting

AEGIS investigates suspicious activities in accordance with applicable laws and internal compliance procedures.

Where required by law or deemed appropriate by the Company, AEGIS may submit Suspicious Activity Reports (SARs), Suspicious Transaction Reports (STRs), or equivalent reports to relevant authorities.

The Company strictly prohibits any form of "tipping off" whereby customers are informed that they are the subject of a compliance review, investigation, or regulatory report.

13. Prohibited Activities

The following activities are strictly prohibited:

  • Money laundering;
  • Terrorist financing;
  • Fraud;
  • Corruption;
  • Sanctions evasion;
  • Human trafficking;
  • Child exploitation;
  • Ransomware activities;
  • Darknet marketplace transactions;
  • Market manipulation;
  • Insider trading;
  • Tax evasion;
  • Unauthorized financial services;
  • Transactions involving proceeds of crime;
  • Any activity prohibited under applicable laws and regulations.

The Company reserves the right to refuse services, freeze assets, restrict wallets, suspend accounts, terminate relationships, and cooperate with authorities where such activities are suspected.

14. Record Retention

AEGIS maintains records relating to:

  • Customer identification;
  • Due diligence documentation;
  • Transaction history;
  • Wallet activity;
  • Compliance reviews;
  • Sanctions screening results;
  • Internal investigations;
  • Suspicious activity reporting.

Such records shall be retained for a minimum of five (5) years following the termination of the customer relationship or completion of the relevant transaction, or longer where required by law.

15. Data Protection and Confidentiality

The Company maintains appropriate safeguards to protect customer information, transaction records, wallet data, and confidential information from unauthorized access, disclosure, misuse, alteration, or loss.

Customer information may only be disclosed:

  • Where required by law;
  • To regulatory authorities;
  • To law enforcement agencies;
  • To compliance service providers;
  • To auditors and professional advisers;

For AML/CFT, fraud prevention, sanctions screening, cybersecurity, or compliance purposes.

16. Reservation of Rights

AEGIS reserves the right, at its sole discretion, to:

  • Request additional information or documentation;
  • Conduct additional due diligence;
  • Refuse onboarding applications;
  • Delay, reject, freeze, block, or reverse transactions;
  • Restrict access to wallets, products, or services;
  • Suspend or terminate customer accounts;
  • Conduct enhanced investigations;
  • File regulatory reports;
  • Cooperate with regulatory, governmental, and law enforcement authorities.

The Company shall not be liable for losses, delays, restrictions, suspensions, or disruptions arising from actions taken in good faith for compliance, regulatory, fraud prevention, cybersecurity, or risk management purposes.

17. Policy Review

This Policy may be reviewed and updated periodically to reflect changes in applicable laws, regulations, industry standards, operational requirements, or emerging financial crime risks.

Continued use of AEGIS Wallet constitutes acceptance of the latest version of this Policy.