Anti Money Laundering Policy

This page is a supplement to the full Conditions of Use provided here.

Last Updated: October 2, 2023

Block Transfer is a transfer agent registered with and regulated by the SEC. We are committed to maintaining the highest standards of Anti-Money Laundering ("AML") practices to prevent and detect money laundering and other illicit financial activities.

This policy sets forth the principles, procedures, and standards that govern our AML efforts. The policy is designed to ensure compliance with the Bank Secrecy Act ("BSA"), the USA PATRIOT Act, the Financial Action Task Force ("FATF") recommendations, and other relevant AML regulations. By adhering to this policy, we safeguard the integrity of our financial operations, foster trust among clients, and uphold our commitment to a secure financial ecosystem.

Client Identity Verification

Block Transfer shall employ the Persona platform and other reliable means to verify the identities of all clients in accordance with the Client Identification Program requirements outlined in the BSA. The identity verification process is multi-layered, aiming to mitigate the risks of identity fraud and impersonation while ensuring the accuracy and completeness of client information.

Global AML and PEP List Scans

To fortify defenses against money laundering and terrorist financing, we conduct periodic and systematic scans against lists of Politically Exposed Persons and known money launderers. By cross-referencing user information with these databases, Block Transfer aims to promptly identify and assess potential associations with individuals or entities involved in illicit financial activities.

Ongoing AML Checks

Block Transfer detects and reports suspicious or unusual activities with a robust ongoing transaction monitoring system, in accordance with Rule 17Ad-7 as promingled by the SEC.

Address Changes and Residency Checks

Block Transfer employs a comprehensive verification program that evaluates address changes and current residencies in a diligent manner to mitigate any potential associations with recognized money laundering destinations. This process is designed to take into account all relevant factors known within our verification program to ensure a robust and effective screening process.

Source of Wealth Review

Block Transfer shall assume that a client's wealth is derived from prior investment holdings unless there is material evidence to the contrary. In the event of detecting suspicious account activity, Block Transfer reserves the right to require further analysis of the client's source of wealth to assess the legitimacy of funds involved.

Continuous Improvement

Block Transfer is committed to continuous improvement of its AML practices. Regular reviews of this policy and updates to procedures shall be undertaken in good faith to ensure alignment with emerging risks, regulatory changes, and advancements in AML technology.