AML & CFT Policy
Effective October 7, 2024
Internset DAO LLC, an algorithmically managed decentralized autonomous organization, is committed to complying with Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) regulations. This policy applies to all activities within the Internset DAO LLC ecosystem, including token transactions, governance operations, and platform interactions. It outlines measures to prevent the misuse of the platform for illicit activities while maintaining the integrity of its decentralized operations.
1. Risk-Based Approach
We adopt a risk-based approach to identify and address risks related to money laundering and terrorism financing. Regular assessments evaluate factors such as user activity, transaction types, and geographical reach, enabling the implementation of appropriate controls. Higher-risk users and transactions are subject to stricter scrutiny to ensure compliance with AML/CFT regulations.
2. Customer Due Diligence (CDD)
Our tiered Customer Due Diligence process ensures compliance through robust Know Your Customer (KYC) verification. Users must provide accurate and verifiable information via trusted third-party services. For higher-risk users or transactions, Enhanced Due Diligence (EDD) is conducted to minimize potential vulnerabilities and uphold the platform’s integrity.
3. Ongoing Monitoring
Monitoring user accounts and transactions is a critical component of our AML/CFT strategy. We employ advanced blockchain analytics tools, such as [Tool Name], to track transaction patterns and flag suspicious activities. Smart contracts embedded with compliance safeguards are used to enforce monitoring protocols. Transaction thresholds are reviewed and updated regularly to trigger further investigations when necessary.
4. Reporting Suspicious Activities
Suspicious activities or unusual transactions are reported promptly to relevant financial intelligence units (FIUs) or regulatory authorities. Reports are handled confidentially to maintain the integrity of investigations, and users are not informed when a report is filed.
5. Record-Keeping
All transaction records, KYC data, and suspicious activity reports are securely maintained for a minimum of five years. These records are organized to ensure they are readily accessible to authorized regulatory bodies when required, demonstrating full compliance with applicable laws.
6. Training and Awareness
Regular AML/CFT training is provided to all DAO members and contributors. Training programs are updated to reflect the latest regulations, industry best practices, and emerging risks. Specialized sessions are conducted for roles involving higher exposure to potential risks, ensuring all participants are equipped to address compliance challenges effectively.
7. Collaboration with Authorities
We maintain open communication and cooperate fully with law enforcement and regulatory bodies to address and prevent illicit activities. Participation in industry forums allows us to share best practices and stay updated on evolving threats and regulations.
8. Periodic Review and Audits
Our AML/CFT policies undergo annual reviews and are updated as needed to reflect significant regulatory changes or operational developments. Regular internal audits, supplemented by external independent reviews, ensure the effectiveness and relevance of our compliance measures.
9. User Responsibilities
Users of the platform are required to comply with AML/CFT requirements by providing accurate and truthful information during KYC verification. Non-compliance, such as providing falsified documents or engaging in suspicious transaction patterns, may result in account suspension or other corrective actions.
10. Cryptocurrency-Specific Measures
We implement specific measures to address risks associated with privacy coins and detect patterns indicative of layering or structuring in cryptocurrency transactions. Blockchain analysis tools are utilized to enhance transaction oversight, ensuring the integrity of the ecosystem.
11. Sanctions Screening
A real-time sanctions screening process ensures compliance with updated international sanctions lists. Screening tools and procedures are regularly updated, and clear guidelines are in place for managing potential sanctions matches in compliance with global standards.
12. Smart Contract Management
Smart contracts deployed on the Polygon Blockchain are designed with embedded AML/CFT safeguards. These contracts are reviewed and updated periodically to maintain alignment with compliance requirements. Governance protocols ensure transparency in modifications and ongoing adherence to AML/CFT standards.
