At Chainchaiser LLC, we are committed to preventing and detecting any illegal financial activities, including money laundering and terrorist financing, through our cryptocurrency services. This AML policy outlines our approach to maintaining compliance with the laws of Saint Kitts and Nevis and international standards.

Our policy applies to all employees, directors, and stakeholders involved in any of our operations. By adhering to this policy, we ensure that our services are not exploited for illicit activities and maintain the highest levels of integrity and compliance.

This AML policy is in compliance with the following laws and international standards:

• The Proceeds of Crime Act (POCA) 2000 of Saint Kitts and Nevis.
• Anti-Money Laundering Regulations (AMLR) of Saint Kitts and Nevis.
• Financial Action Task Force (FATF) Recommendations.
• United Nations Anti-Terrorism Measures.
• Financial Intelligence Unit (FIU) Guidelines of Saint Kitts and Nevis.

We perform thorough Know Your Customer (KYC) and Customer Due Diligence (CDD) checks for all clients to prevent illegal activities. This includes:

• Verifying the identities of clients through official documents.
• Identifying the nature and purpose of client relationships.
• Conducting Enhanced Due Diligence (EDD) for high-risk clients, such as Politically Exposed Persons (PEPs) or those from high-risk jurisdictions.

We conduct annual risk assessments to identify, evaluate, and mitigate risks associated with money laundering and terrorist financing. We assess factors such as:

• Geographic Risk: Regions with elevated levels of financial crime.
• Transaction Risk: Large-value or complex transactions.
• Client Risk: High-risk clients, such as PEPs or entities from high-risk jurisdictions.

Our real-time transaction monitoring system continuously tracks all activities on our platform. This system flags suspicious transactions such as:

• Large or irregular transactions.
• Transactions involving high-risk individuals or jurisdictions.
• Signs of money laundering patterns, such as structuring (breaking large transactions into smaller amounts).
• All flagged transactions are promptly reviewed by the Compliance team and necessary actions are taken, including account limitations if required.

We implement strict sanctions screening to ensure that we do not engage with sanctioned individuals, entities, or countries. Our sanctions screening system checks clients and transactions against global sanctions lists from organizations such as the United Nations (UN) and Office of Foreign Assets Control (OFAC).

If a match is found, we immediately freeze the transaction and notify the relevant authorities.

To ensure full compliance, Chainchaiser LLC provides ongoing AML training to all employees. This includes:

• Recognizing and reporting suspicious activities.
• Understanding CDD and EDD processes.
• Staying updated on changes to AML regulations.

All employees must complete training upon joining and participate in regular refresher courses.

We conduct due diligence on all third-party relationships to ensure they meet our AML standards. This includes evaluating their AML policies, reviewing their regulatory compliance, and monitoring their transactions. We reserve the right to terminate relationships with non-compliant third parties.

At Chainchaiser LLC, we fully cooperate with law enforcement agencies and regulatory authorities in their efforts to combat money laundering, terrorist financing, and other illegal activities. Upon receiving a lawful request, we are committed to:

• Providing Information: Supplying relevant customer information, transaction details, and account records as required by law, while respecting data privacy laws.
• Responding Promptly: Ensuring timely and accurate responses to law enforcement inquiries or subpoenas in accordance with the legal framework of Saint Kitts and Nevis.
• Confidentiality: Ensuring that customer information is handled securely and confidentially when responding to law enforcement requests.

Chainchaiser LLC complies with the Proceeds of Crime Act, FIU guidelines, and other applicable laws in Saint Kitts and Nevis that govern the disclosure of information to authorities. We maintain clear internal procedures to ensure the swift processing of such requests while adhering to legal obligations.

Contact email - [email protected]

Our AML policy is reviewed annually or when there are significant changes in regulations or company operations. All updates are communicated to employees, and the latest version of the policy is always implemented across the company.

Non-compliance with this AML policy may result in disciplinary actions, including termination, fines, or legal action. We take violations of AML regulations seriously and report any serious breaches to the Financial Intelligence Unit (FIU) in Saint Kitts and Nevis.