Anti-Money Laundering (AML) Policy

Last Updated: February 19, 2026

VaultPay is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our approach to preventing the misuse of our platform for illegal activities.

1. Introduction

Money laundering is the process of concealing the origins of illegally obtained money. Terrorist financing involves providing funds for terrorist activities. Both are serious criminal offenses that VaultPay is committed to preventing.

This AML Policy applies to all users, employees, and third parties associated with VaultPay.

2. Regulatory Framework

Our AML program is designed to comply with:

• Financial Action Task Force (FATF) recommendations
• Applicable national and international AML/CTF laws
• Know Your Customer (KYC) requirements
• Sanctions compliance regulations

3. Know Your Customer (KYC) Requirements

All users must complete identity verification, which includes:

3.1 Basic Verification

• Full legal name
• Date of birth
• Email address verification
• Phone number verification

3.2 Enhanced Verification

• Government-issued photo ID (passport, driver's license, or national ID)
• Proof of address (utility bill, bank statement dated within 3 months)
• Selfie verification with ID document
• Source of funds documentation (for high-value transactions)

4. The 8% Verification Requirement

4.1 Purpose of This Requirement

This requirement serves multiple purposes:

• Source of Funds Verification: Ensures that funds originate from legitimate, verified sources
• Fraud Prevention: Helps prevent stolen funds from being laundered through our platform
• Regulatory Compliance: Meets international AML standards for cryptocurrency transactions
• Risk Mitigation: Reduces the risk of our platform being used for illicit activities

4.2 How It Works

1. Before withdrawing, ensure you have completed KYC verification on a recognized exchange
2. Maintain at least 8% of your intended withdrawal amount on that verified exchange
3. The funds on the verified exchange serve as proof of legitimate source
4. This verification is checked automatically when processing withdrawals

4.3 Example

If you wish to withdraw 1 BTC:

• You must have at least 0.08 BTC (8%) on a verified exchange like Binance, Coinbase, or Kraken
• Your account on that exchange must be fully KYC verified
• This demonstrates that you have access to verified funds

5. Transaction Monitoring

We continuously monitor transactions for suspicious activity, including:

• Unusual transaction patterns or volumes
• Transactions involving high-risk jurisdictions
• Structuring (breaking up large transactions to avoid reporting)
• Rapid movement of funds
• Transactions with known illicit addresses

6. Suspicious Activity Reporting

We are obligated to report suspicious activities to relevant authorities. This includes:

• Transactions that appear to involve proceeds of crime
• Attempts to avoid KYC requirements
• Unusual account activity inconsistent with stated purpose
• Links to known criminal or terrorist organizations

7. Sanctions Compliance

We screen all users and transactions against:

• OFAC (Office of Foreign Assets Control) sanctions lists
• UN Security Council sanctions lists
• EU sanctions lists
• Other applicable national sanctions programs

8. Record Keeping

We maintain records of:

• User identification documents
• Transaction records
• KYC verification results
• Suspicious activity reports

Records are retained for a minimum of 5 years after the business relationship ends.

9. Training

All VaultPay employees receive regular AML training covering:

• Recognition of suspicious activities
• KYC procedures
• Reporting obligations
• Regulatory updates

10. Risk Assessment

We conduct regular risk assessments considering:

• Customer risk profiles
• Geographic risks
• Product/service risks
• Delivery channel risks

11. High-Risk Activities

The following are considered high-risk and subject to enhanced scrutiny:

• Large or frequent transactions
• Transactions involving privacy coins
• Users from high-risk jurisdictions
• Politically Exposed Persons (PEPs)
• Unusual transaction patterns

12. User Responsibilities

Users are required to:

• Provide accurate and complete information
• Update information promptly when changes occur
• Not use our platform for illegal activities
• Comply with all KYC requirements
• Report any suspicious activity they observe

13. Consequences of Non-Compliance

Violations of this AML Policy may result in:

• Account suspension or termination
• Freezing of assets pending investigation
• Reporting to law enforcement authorities
• Legal action

14. Contact Information

For questions about our AML Policy or to report suspicious activity:

Email: compliance@vaultpay.io

Compliance Officer: VaultPay Compliance Team

15. Policy Updates

This policy is reviewed and updated regularly to reflect changes in regulations and best practices. Users will be notified of significant changes.