🛡️ AML/CTF & Sanctions Policy — Chaiger Ecosystem

AML/CTF & SANCTIONS POLICY

Version: 1.0 • Effective Date: 2025-08-16 • Compliance: contact [email protected]

PURPOSE AND SCOPE

Principles against money laundering, terrorist financing, and sanctions compliance (FATF, OFAC, EU, UK-HMT, SECO/CH, and equivalents). Applies to users, partners, and operations related to the ecosystem.

RISK-BASED APPROACH

Risk classification (user, geography, product — staking, marketplace, affiliates, Phase 1 redemption, Phase 2 conversions), volume, and behavior. Graduated diligence measures.

ELIGIBILITY AND RESTRICTED JURISDICTIONS

Access prohibited from sanctioned countries/territories and listed individuals.
Redemptions (Phase 1) and conversions (Phase 2) may be unavailable in certain jurisdictions.

DUE DILIGENCE (CDD/EDD) AND VERIFICATIONS

— KYC (Individuals): identity, selfie/liveness, PEP, sanctions, proof of address (where applicable).
— KYB (Entities): incorporation docs, UBOs, directors, sanctions/PEP.
— EDD: high risk (PEPs, high-risk countries, high volumes, suspicious patterns).
— Revalidation based on risk level.

MONITORING AND RED FLAGS

— Unusual patterns: bursts, mixers, suspicious bridging, high-risk chains/DEXs, wash trading, abuse in Phase 1 redemption (multi-accounts, sybil, artificial farming).
— On-chain heuristics (flagged addresses, clustering) and reports from analytics providers.

TRAVEL RULE AND VASP QUALIFICATION

— Chaiger is non-custodial by design; when applicable to transfers between VASPs or on/off-ramp integrations in Phase 2, we will apply the Travel Rule through compatible providers.
— VASP partners must maintain compliance and interoperability.

SANCTIONS AND SCREENING

— Screening at onboarding (when applicable) and ongoing (OFAC/EU/UK/UN/SECO).
— Blocking of programmable benefits, restricted access, and reporting where required.

RECORDKEEPING AND RETENTION

— Records of KYC/KYB, verifications, and suspicious activity reports retained for the legal period (up to 10 years, depending on jurisdiction).

REPORTING AND COOPERATION

— Reports to competent authorities when required.
— Response to valid judicial/administrative orders.

AFFILIATE PROGRAM

— KYC required above thresholds; prohibition of marketing in restricted jurisdictions; ban on profit guarantees and promotion of redemptions/conversions as financial gain.

TRAINING AND AUDIT

— Annual training; periodic review (at least annually) and compliance audits.

DISCIPLINARY AND RISK MEASURES

— Account termination/suspension due to AML/CTF risk.
— Refusal to engage with high-risk partners.

COMPLIANCE CONTACT

[email protected]