Built on Trust.
Regulated by Design.

Customer Identification Program (CIP): We verify the identity of all customers using government-issued identification, biometric verification, and address confirmation. Our risk-based tiering applies Standard Due Diligence (SDD) for low-risk clients, Enhanced Due Diligence (EDD) for high-risk clients, and ongoing monitoring for all accounts. Verification is completed through our integrated partner, Jumio, with manual review by our compliance team for escalated cases.

Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD): We assess the risk profile of each customer relationship across multiple dimensions including geographic risk, transaction patterns, source of funds, occupation, and expected account activity. High-risk accounts — including PEPs (Politically Exposed Persons), high-net-worth individuals, and accounts with complex ownership structures — receive enhanced due diligence with ongoing senior-level review.

OFAC Sanctions Screening: All customers, counterparties, and transactions are screened in real-time against OFAC's Specially Designated Nationals (SDN) list, the Consolidated Sanctions List, and other applicable sanctions programs including EU, UK, and UN sanctions lists. Blockchain-specific screening is conducted through Chainalysis KYT (Know Your Transaction) and Chainalysis Reactor for on-chain analytics, wallet risk scoring, and counterparty identification.

Suspicious Activity Reporting (SAR): We maintain robust procedures for identifying, documenting, escalating, and reporting suspicious activity to FinCEN. All employees receive annual BSA/AML training with role-specific modules for customer-facing staff, compliance personnel, and senior management. Our SAR filing process includes automated transaction monitoring with tuned rule sets, manual case investigation, and a 30-day filing timeline for confirmed suspicious activity.

Currency Transaction Reporting (CTR): We file Currency Transaction Reports for all transactions exceeding $10,000 in a single business day, as well as structured transaction reports for patterns designed to evade reporting thresholds.

Travel Rule Compliance: For digital asset transfers exceeding $3,000, we collect and transmit originator and beneficiary information in compliance with FinCEN's Travel Rule and FATF Recommendation 16, using the TRUST (Travel Rule Universal Solution Technology) protocol for interoperability with other virtual asset service providers.

Record Retention: All CIP, CDD, SAR, and CTR records are retained for a minimum of five (5) years after account closure or transaction date, as required by BSA regulations. Records are stored in encrypted, access-controlled systems with full audit trails.

Independent Testing: Our AML program undergoes annual independent testing by Kroll Associates, a nationally recognized audit firm, to evaluate the adequacy of our controls, policies, and procedures. Findings are reported to the Board of Directors and remediated within established timeframes.

Our BSA/AML Compliance Officer, Jennifer Walsh, CAMS, CFE, holds over 12 years of experience in financial crimes compliance and reports directly to the Chief Compliance Officer and the Board of Directors.