Anti-Money Laundering Policy

1. Purpose and Commitment

Ledgelo is committed to preventing money laundering, terrorist financing, and other illicit activities. This Anti-Money Laundering (AML) Policy outlines our approach to detecting and preventing financial crimes in compliance with applicable laws and regulations.

We maintain robust systems and controls to identify, assess, and manage money laundering and terrorist financing risks associated with our cryptocurrency swap services.

2. Risk-Based Approach

We employ a risk-based approach to AML compliance, which includes:

• Continuous transaction monitoring for suspicious patterns
• Risk scoring of transactions based on multiple factors
• Enhanced due diligence for high-risk transactions
• Regular updates to our risk assessment methodologies
• Partnership with blockchain analytics providers

3. Know Your Transaction (KYT)

We utilize Know Your Transaction (KYT) procedures to monitor and analyze cryptocurrency transactions. This includes:

• Blockchain analysis to trace fund origins and destinations
• Screening against sanctions lists and known illicit addresses
• Identifying patterns associated with money laundering
• Monitoring for mixing services and high-risk exchanges
• Real-time risk scoring of wallet addresses

4. Know Your Customer (KYC)

While Ledgelo operates as a non-custodial service without mandatory registration, KYC verification may be required in certain circumstances:

• Transactions exceeding certain thresholds
• Transactions flagged as high-risk by our monitoring systems
• Addresses associated with suspicious activity
• Compliance with specific regulatory requirements
• User requests for increased transaction limits

If KYC is required, you will be notified and asked to provide appropriate identification documentation. Transactions may be held or declined until verification is complete.

KYC thresholds are determined by our partner providers and may vary based on risk assessment, transaction patterns, and regulatory requirements.

5. Prohibited Activities

The following activities are strictly prohibited:

• Money laundering or attempting to disguise illicit funds
• Terrorist financing or support for sanctioned entities
• Transactions involving darknet markets or illegal services
• Fraud, theft, or handling of stolen cryptocurrency
• Ransomware payments or extortion-related transactions
• Circumventing sanctions or embargoes
• Use of mixing services to obscure transaction origins

6. Sanctions Compliance

We maintain comprehensive sanctions screening, including:

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

Transactions involving sanctioned countries, entities, or individuals will be blocked and may be reported to relevant authorities.

7. Geographic Restrictions

We implement geographic restrictions through IP detection and may require additional verification to ensure compliance with these restrictions.

8. Suspicious Activity Reporting

We are committed to reporting suspicious activities to relevant authorities. Indicators of suspicious activity include:

• Unusual transaction patterns or volumes
• Connections to known illicit addresses
• Attempts to circumvent verification procedures
• Transactions inconsistent with stated purposes
• Use of multiple addresses to avoid thresholds

9. Record Keeping

We maintain records of transactions and any KYC documentation for the period required by applicable laws, typically a minimum of five years. These records may be made available to law enforcement and regulatory authorities upon legitimate request.

10. Staff Training

Our team receives regular training on AML procedures, including identification of suspicious activities, sanctions compliance, and proper reporting procedures. We maintain up-to-date knowledge of evolving money laundering techniques and regulatory requirements.

11. User Responsibilities

By using our service, you agree to:

• Provide accurate information when requested
• Not use our service for any prohibited activities
• Cooperate with any verification procedures
• Not attempt to circumvent our AML controls
• Report any suspicious activity you encounter