AML/KYC Policy

1. Policy Statement & Purpose 2. Designated MLRO 3. Risk Assessment 4. Customer Due Diligence (CDD/KYC) 5. Transaction Monitoring 6. Suspicious Activity Reporting 7. Sanctions Screening 8. Record Keeping 9. Staff Training 10. Policy Review

Section 1 — Policy Statement & Purpose

Eldeeb Tech LLC ("the Company") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy establishes procedures to prevent the use of our services for money laundering, terrorist financing, or other financial crimes.

Applicable Regulations:

Bank Secrecy Act (BSA) — United States
USA PATRIOT Act — Sections 311-319, 326
FATF Recommendations on Virtual Assets
FinCEN Guidance on Virtual Currency
Wyoming Digital Assets Act (W.S. §34-29-101 et seq.)

Section 2 — Designated MLRO

The Money Laundering Reporting Officer (MLRO) is Kareem Eldeb, CEO and Sole Managing Member. The MLRO oversees all AML compliance activities including suspicious activity monitoring, staff training, and regulatory reporting.

Section 3 — Risk Assessment

3.1 Risk-Based Approach

The Company adopts a risk-based approach proportionate to the nature and scale of our operations in digital asset services.

3.2 Risk Factors Considered

Customer type (individual, corporate, PEP, high-risk jurisdiction)
Transaction volume, size, and frequency
Geographic risk (FATF high-risk jurisdictions, sanctioned countries)
Product/service risk (digital assets, cross-border transfers)
Delivery channel risk (online, mobile, anonymous)

Section 4 — Customer Due Diligence (CDD/KYC)

4.1 Customer Identification

All customers must provide the following before engaging in transactions:

Government-issued photo ID — passport, national ID, or driver's license
Proof of address — utility bill or bank statement (within 3 months)
For entities: Company registration documents, beneficial ownership information

4.2 Enhanced Due Diligence (EDD)

EDD is triggered for:

Politically Exposed Persons (PEPs) and their associates
Customers from high-risk jurisdictions
Transactions exceeding $10,000 or equivalent
Complex or unusual transaction patterns

Section 5 — Transaction Monitoring

Automated monitoring systems flag transactions based on:

Unusual transaction size or frequency
Transactions involving sanctioned addresses
Structuring patterns (multiple small transactions to avoid thresholds)
Rapid movement of funds through multiple wallets

All flagged transactions are manually reviewed by the MLRO within 24 hours. Suspicious transactions are frozen pending investigation.

Section 6 — Suspicious Activity Reporting

Suspicious Activity Reports (SARs) are filed with FinCEN within 30 days of detection. The Company maintains absolute confidentiality regarding SAR filings — no customer or employee may be informed of a SAR filing.

Section 7 — Sanctions Screening

All customers and transactions are screened against:

OFAC Specially Designated Nationals (SDN) List
UN Security Council Sanctions Lists
EU Consolidated Sanctions List
FATF High-Risk and Non-Cooperative Jurisdictions

Section 8 — Record Keeping

All KYC documents, transaction records, and compliance reports are retained for a minimum of 5 years following account closure or last transaction.

Section 9 — Staff Training

All employees with access to customer data or financial operations receive AML training upon hire and annually thereafter, covering red flag identification, reporting procedures, and regulatory updates.

Section 10 — Policy Review

This policy is reviewed annually or upon significant regulatory changes. Last review: August 2026.

Questions about our AML/KYC compliance?

[email protected] · @EldeebCoin

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