AML Policy

1. Purpose

The purpose of this Anti–Money Laundering (AML) Policy is to establish the principles, controls, and procedures that Coin Funded ("the Company") applies to prevent and detect money laundering, terrorist financing, and other financial crimes. This policy also fulfills all regulatory and institutional requirements related to AML and Counter-Terrorism Financing (CTF) compliance.

2. Scope

This policy applies to all employees, contractors, traders, and affiliates of Coin Funded. It governs all products, services, and transactions involving both fiat and digital assets, across all jurisdictions in which the Company operates.

3. Governance and AML Program

Coin Funded has established a comprehensive AML Program, approved by senior management.

• The AML Program includes formal policies, practices, and procedures to prevent, detect, and report suspicious transactions.
• The Company applies its AML framework to all subsidiaries, branches, and partners—both domestically and internationally.
• The Company maintains compliance with all applicable anti–money laundering and anti–terrorist financing laws in its jurisdiction.

4. Designated AML Compliance Officer

The Company has appointed a designated AML Team responsible for oversight and enforcement of this policy:

The AML Team is responsible for:

• Ensuring ongoing compliance with AML/CTF regulations
• Overseeing KYC, transaction monitoring, and reporting processes
• Reviewing and updating AML policies
• Providing staff training and maintaining records
• Acting as liaison with regulators and law enforcement

5. Customer Due Diligence (CDD) and Know Your Customer (KYC)

Coin Funded implements a risk-based approach to customer verification and monitoring, including:

• Collection and verification of all client identification data (name, DOB, address, government ID).
• Collection of proof of address and business activity information.
• Establishment of a full customer profile and risk rating upon onboarding.
• Maintenance of KYC records and identification documents for at least five (5) years.
• Steps to understand the normal and expected transactional behavior of each customer.
• Application of Enhanced Due Diligence (EDD) for high-risk customers, such as:

• Politically Exposed Persons (PEPs) and their close associates
• Customers located in or transacting with high-risk jurisdictions
• Unusual or complex transactions

The Company may rely on approved third parties to collect Customer Identification Program (CIP) information, provided they meet AML standards.

6. Politically Exposed Persons (PEPs)

Coin Funded maintains a dedicated PEP Policy that covers relationships with politically exposed persons, their families, and close associates. Enhanced due diligence is applied, including management approval and ongoing monitoring of PEP-related accounts.

7. Risk Assessment

The Company conducts ongoing risk-focused assessments of customers, products, services, geographic exposure, and distribution channels.

Key elements include:

• Periodic review of risk models and thresholds
• Enhanced monitoring for higher-risk categories
• Identification of exposure to High-Intensity Drug Trafficking Areas (HIDTA) or High-Intensity Financial Crime Areas (HIFCA) — none currently applicable to Coin Funded

8. Suspicious Activity Monitoring and Reporting

Coin Funded maintains a formal Monitoring Program to identify unusual or suspicious activities, using a combination of automated systems and manual reviews.

• The system flags anomalies such as irregular trading behavior, inconsistent deposits, or rapid movement of funds.
• The AML Team investigates and, where appropriate, files Suspicious Activity Reports (SARs) with relevant authorities.
• The Company has procedures to identify structuring or smurfing designed to evade reporting thresholds.
• Suspicious activities involving cash equivalents or crypto transfers are subject to heightened scrutiny.

9. Sanctions Screening

Coin Funded screens all customers and counterparties during onboarding and on an ongoing basis using a sanctions screening solution (e.g., SumSub, ComplyAdvantage, or internal screening tools).

Screening includes:

• Global sanctions lists (OFAC, UN, EU, HMT, etc.)
• Section 314(a) matches
• PEPs and their associates
• Terrorist and criminal watchlists

All confirmed matches are escalated to the AML Officer and, where appropriate, reported to the relevant authorities.

10. Prohibited Relationships

Coin Funded prohibits relationships with the following:

• Shell banks (institutions without physical presence or regulatory affiliation)
• Anonymous accounts or clients
• Clients using privacy-enhancing tools intended to obscure fund origins (e.g., mixers, tumblers)

11. Record Retention

All AML-related records—including customer identification, due diligence data, transaction reports, and training records—are retained securely for at least five (5) years or longer as required by law.

12. Independent Review and Internal Audit

Coin Funded maintains an internal audit function and may engage independent third parties to assess AML policies, procedures, and effectiveness on a regular basis. These reviews ensure continued compliance and improvement of the AML framework.

13. AML Training

All relevant employees receive mandatory AML and CTF training on at least an annual basis.

• Training includes detection and reporting of suspicious activity, handling of PEPs, sanctions awareness, and internal reporting procedures.
• The Company maintains full training records, including materials and attendance logs.

14. Regulatory Oversight

Coin Funded has not yet been subject to a formal AML regulatory examination, but maintains full readiness and documentation for future inspections.

15. Program Review and Approval

This AML Policy is reviewed annually and upon material changes in business operations or regulations. Any amendments are approved by the Managing Director or designated senior management.