Anti-money Laundering

Scope and Purpose

333a maintains an anti-money laundering (AML) program designed to prevent the use of the platform for money laundering, terrorist financing, or other unlawful activity. This policy sets out the obligations of 333a, the standards for customer due diligence, ongoing monitoring, and the actions taken when AML concerns arise.

Regulatory Compliance and Governance

333a implements a risk‑based AML framework aligned with applicable laws and FATF guidance. Oversight is provided by the Compliance function, with procedures for escalation, control testing, and reporting to the competent authorities as required by law. The policy is reviewed at least annually and upon material regulatory change.

Definitions

  • Money laundering: techniques intended to conceal the proceeds of crime or facilitate the funding of illicit activities.
  • Terrorist financing: providing or moving funds to enable acts of terrorism or related activities.
  • Politically Exposed Persons (PEP): individuals who, or whose family members or close associates, hold prominent public functions or equivalent roles.
  • Know Your Customer (KYC): processes to verify a customer’s identity and assess risk before and during business relationships.
  • Due Diligence (CDD/EDD): standard and enhanced procedures used to verify identity and assess risk based on customer type, geography, and expected activity.
  • Source of Funds/Wealth: the origin of the funds used for deposits and ongoing activity.
  • Suspicious activity: patterns or behaviors that raise reasonable suspicion of illicit activity.

KYC and Verification

All customers are subject to KYC verification. The minimum data set includes:

  • Full name
  • Date of birth
  • Nationality
  • Permanent residence address
  • Government-issued identifier (ID number)

Required documents may include:

  • Valid passport or national identity card
  • Document verifying address (utility bill, bank statement, or equivalent)

Additional documents may be requested to support the verification process. 333a may perform third‑party checks, including regulatory or credit‑type verifications, using information provided by the customer. During verification, access to certain withdrawal functions may be restricted until verification is complete. If provided information is false, incomplete, or does not match the customer’s identity, 333a reserves the right to suspend or terminate the account and deny service beyond the scope of verification requirements.

Risk-Based Approach and Customer Classification

333a applies a risk‑based approach to customer assessment, taking into account jurisdictional risk, customer type, and activity patterns. Risk categories may include low, medium, and high. The company conducts ongoing monitoring to identify indicators of risk, including:

  • Sanctions or adverse regulatory findings related to the customer’s jurisdiction
  • PEP status or related associations
  • Unusual or inconsistent activity, rapid growth in deposits, or other suspicious patterns

Enhanced due diligence is performed for higher‑risk customers, with senior management approval required for final determinations in some cases.

Source of Funds and Source of Wealth

Customers must provide credible evidence of the origin of funds used for deposits and ongoing activity. Acceptable evidence includes:

  • Salary statements or compensation records
  • Formal documents showing other regular income
  • Bank statements or savings records reflecting the accumulation of funds
  • Proof of wealth from verifiable sources (e.g., business income, inheritance, pensions) with clear linkage to deposited funds

Where deposits or earnings appear inconsistent with known sources, 333a may request additional documentation or clarification before allowing continued activity.

Politically Exposed Persons (PEP) Policy

Customers classified as PEPs, or their family members or close associates, are subject to enhanced due diligence. The company reserves the right to restrict or terminate services for PEPs if risk assessment warrants. If a customer is subsequently identified as a PEP, the account may be subject to heightened scrutiny, and controls shall be adjusted accordingly in accordance with applicable laws.

Account Monitoring and Transaction Monitoring

Ongoing monitoring is conducted to detect suspicious activity. Suspicious indicators include, but are not limited to:

  • Unusual deposit patterns or rapid changes in funding sources
  • Use of multiple devices or payment methods to access the account
  • Geolocation discrepancies or device ID anomalies
  • Attempted withdrawals while verification is incomplete

Any detected activity is reviewed by the AML team. If warranted, transactions may be blocked, investigated, or reported to the competent authorities in accordance with legal obligations.

Transaction Monitoring and Payment Integrity

All deposits and withdrawals are reconciled against customer identity. Specific controls include:

  • Card payments: account name must match the cardholder name
  • Electronic wallets: wallet email must match the account email
  • Anonymous or untraceable payment instruments are not accepted
  • Withdrawals must be directed to the original payment instrument or a verified banking account linked to the customer

333a does not process funds from anonymous sources or allow transfers to third parties not linked to the customer's ownership chain.

Record-Keeping and Data Protection

All verification documents, identity data, and transaction records are kept in accordance with applicable data protection laws and regulatory requirements. Access to records is restricted to authorized personnel. Data may be shared with competent authorities or regulators as required by law or policy, subject to applicable privacy protections in the relevant jurisdiction.

Sanctions and Compliance Screening

333a screens customers and transactions against applicable sanctions and watch lists. If a match is identified, all relevant activity is paused and reported to the appropriate authorities in accordance with law.

Amendments and Communications

This policy may be amended from time to time. Customers will be notified of material changes in accordance with the Terms and Conditions. Continued use of the service after notification constitutes acceptance of the updated policy.

Responsibilities, Reporting, and Cooperation

The Compliance and Risk teams are responsible for implementing this policy, maintaining records, and ensuring regulatory reporting where required. 333a will cooperate with authorities and provide information consistent with legal obligations and data protection rules.

Training and Audit

333a provides AML training to staff and conducts periodic independent and internal audits to test the effectiveness of the AML program and to identify and remediate gaps in controls.

Contact Information

Customers may contact the Compliance team via the channels provided in the account portal for any AML-related queries, or to report concerns related to potential illicit activity. All inquiries will be handled in accordance with applicable privacy and data protection laws.