🏛️ Anti-Money Laundering (AML) & KYC Policy

Registration & Regulatory Compliance

SPNID, LLC is a company registered in the State of Wyoming (USA) operating in full compliance with the Bank Secrecy Act (BSA) and Financial Crimes Enforcement Network (FinCEN) regulations.

Anti-Money Laundering (AML) Program

SPNID maintains a comprehensive AML program compliant with the Bank Secrecy Act (31 USC §5311 et seq.) and FinCEN regulations. Our program includes:

• Designated Compliance Officer responsible for implementing and overseeing the AML program.
• Internal policies and procedures for the prevention, detection, and reporting of suspicious activities.
• Ongoing staff training on AML regulations and best practices.
• Independent audit of the AML program on a periodic basis to ensure effectiveness.
• Risk-based controls: verification measures are proportionate to the risk level of the transaction and user.

Identity Verification (KYC) Procedures

SPNID applies a tiered KYC procedure proportionate to the volume and type of transactions:

Basic Level — Account Registration

• Email address verification via confirmation link.
• Collection of basic information (first name, last name, country of residence).

Intermediate Level — Sellers & Transactions > $3,000

• Valid photo identification document (passport, national ID, driver's license).
• Proof of residence (utility bill, bank statement — no older than 3 months).
• Phone number verification.

Advanced Level — Transactions > $10,000

• Enhanced Due Diligence (EDD): in-depth verification of the source of funds.
• Screening against international sanctions lists (OFAC, EU, UN).
• Additional documentation on the source of funds may be requested.

Transaction Monitoring

SPNID uses automated and manual systems for continuous transaction monitoring:

• Automated detection of anomalous patterns (high amounts, unusual frequency, suspicious geolocation).
• Counterparty verification to ensure they do not appear on sanctions lists.
• Transaction limits: exceeding thresholds automatically triggers additional verifications.
• Manual review of transactions flagged by the automated system.

Suspicious Activity Reporting

In compliance with the BSA, SPNID is required to file Suspicious Activity Reports (SAR) with FinCEN when it identifies potentially illicit activity. SARs are confidential and are not disclosed to the user involved.

Record Keeping

In compliance with the BSA, SPNID retains the following records:

• User identification data: for at least 5 years from account closure.
• Transaction records: for at least 5 years from the transaction date.
• Copies of filed SARs: for at least 5 years from the filing date.

Sanctions Compliance (OFAC)

SPNID complies with all sanctions imposed by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury:

• Automated screening of all users and transactions against SDN (Specially Designated Nationals) and other sanctions lists.
• Immediate blocking of transactions involving sanctioned persons or entities.
• Reporting to OFAC of any confirmed match.

Staff Training

All SPNID employees and contractors receive periodic training on AML/KYC regulations, internal procedures, and recognition of suspicious activities. Training is updated annually and whenever significant regulatory changes occur.