AML & KYC Policy

1. Overview and Commitment

NAQSN CRYPTO GROUP LTD ("NAQSN") is committed to maintaining the highest standards of Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance. We implement robust procedures to prevent our platform from being used for money laundering, terrorist financing, or other illicit activities.

Our AML/KYC program is designed to comply with applicable laws and regulations, including but not limited to the Bank Secrecy Act (BSA), USA PATRIOT Act, and guidance from the Financial Crimes Enforcement Network (FinCEN).

2. Customer Identification Program (CIP)

All customers must complete our identity verification process before accessing platform services. Our CIP requires:

Individual Customers

• Full legal name as it appears on government-issued identification
• Date of birth
• Residential address
• Government-issued photo identification (passport, driver's license, or national ID)
• Proof of address (utility bill, bank statement, or government correspondence)
• Social Security Number or Tax Identification Number (where applicable)

Institutional Customers

• Legal entity name and registration details
• Business registration documents
• Articles of incorporation or equivalent documents
• Beneficial ownership information (individuals owning 25% or more)
• Authorized representative identification and authorization
• Business license and regulatory approvals (where applicable)

3. Enhanced Due Diligence (EDD)

We apply enhanced due diligence measures for higher-risk customers, including:

• Politically Exposed Persons (PEPs) and their close associates
• Customers from high-risk jurisdictions
• High-volume or high-value transaction customers
• Customers with unusual transaction patterns
• Non-resident customers
• Correspondent banking relationships

EDD may include additional documentation requirements, source of funds verification, and ongoing monitoring.

4. Ongoing Monitoring and Screening

We continuously monitor customer activities and transactions for suspicious patterns:

Transaction Monitoring

• Real-time transaction screening against predefined rules
• Pattern analysis for unusual trading behavior
• Volume and frequency monitoring
• Cross-referencing with known risk indicators
• Machine learning algorithms for anomaly detection

Sanctions Screening

• OFAC (Office of Foreign Assets Control) sanctions lists
• UN Security Council consolidated list
• EU consolidated sanctions list
• Other applicable government sanctions lists
• Politically Exposed Persons (PEP) databases
• Adverse media and negative news screening

5. Suspicious Activity Reporting

We are committed to detecting and reporting suspicious activities. Activities that may trigger investigation include:

• Transactions involving known criminal entities or addresses
• Structuring transactions to avoid reporting thresholds
• Unusual trading patterns inconsistent with customer profile
• Rapid movement of funds without apparent business purpose
• Use of privacy coins or mixing services
• Transactions to or from high-risk jurisdictions
• Customer reluctance to provide required information

When suspicious activity is identified, we will file Suspicious Activity Reports (SARs) with FinCEN and other applicable authorities as required by law.

6. Record Keeping

We maintain comprehensive records as required by applicable regulations:

• Customer identification and verification documents
• Transaction records and supporting documentation
• AML/KYC policy and procedure documentation
• Training records for staff and management
• Suspicious activity reports and investigations
• Correspondence with regulatory authorities

Records are retained for a minimum of five years or as otherwise required by applicable law, with appropriate security measures to ensure confidentiality and integrity.

7. Training and Awareness

All NAQSN personnel receive regular AML/KYC training to ensure they understand their obligations and can effectively identify and respond to potential compliance issues. Training covers current regulations, emerging threats, and best practices in financial crime prevention.

8. Compliance Officer

NAQSN has designated a Chief Compliance Officer responsible for overseeing our AML/KYC program, ensuring regulatory compliance, and serving as the primary contact with regulatory authorities. The Compliance Officer reports directly to senior management and has sufficient authority and resources to implement and maintain our compliance program.

9. Customer Obligations

As a customer, you agree to:

• Provide accurate and complete information during registration
• Update your information promptly when changes occur
• Respond to additional verification requests when necessary
• Not use our services for illegal activities
• Report any suspicious activity you become aware of
• Comply with applicable laws in your jurisdiction

10. Prohibited Activities

The following activities are strictly prohibited on our platform:

• Money laundering or terrorist financing
• Sanctions evasion or prohibited jurisdictions
• Drug trafficking or other illegal commerce
• Fraud, counterfeiting, or identity theft
• Tax evasion or unreported income
• Ransomware payments or cybercrime proceeds
• Market manipulation or insider trading

11. Account Restrictions and Closures

We reserve the right to restrict, suspend, or close accounts that fail to meet our AML/KYC requirements or engage in prohibited activities. We may also freeze funds pending investigation or as required by law enforcement or regulatory authorities.

12. Regulatory Cooperation

NAQSN cooperates fully with law enforcement and regulatory authorities in their investigations. We may disclose customer information when required by law, court order, or valid regulatory request.

13. Policy Updates

This AML/KYC policy is subject to regular review and updates to reflect changes in regulations, best practices, and our business operations. Material changes will be communicated to customers through our platform.

14. Contact Information

For AML/KYC related questions or to report suspicious activity, contact our Compliance team at compliance@naqsn.com.