AML & KYC POLICY

1. Purpose

This Anti-Money Laundering and Know Your Customer Policy (the “Policy”) sets out the principles, procedures, and controls implemented by HIKARICP (the “Company”, “we”, “us”, or “our”) to prevent, detect, and mitigate risks associated with:

• Money laundering

• Terrorist financing

• Proliferation financing

• Fraud

• Sanctions evasion

• Other illicit financial activities

This Policy is designed in accordance with international best practices, including the Financial Action Task Force (FATF) recommendations.

2. Scope

This Policy applies to:

• All Users of HIKARICP

• All employees, contractors, and officers

• All products and services, including:

  • Spot trading

  • Futures and margin trading

  • Staking and earn products

  • Custodial wallet services

3. Regulatory Framework

Although HIKARICP operates under the laws of the Republic of Seychelles, the Company voluntarily aligns its AML and KYC framework with international standards, including:

• FATF Recommendations

• Risk-based compliance approach

• International sanctions regimes

• Cross-border compliance principles

This Policy may be updated to reflect regulatory changes or operational needs.

4. Risk-Based Approach

HIKARICP adopts a risk-based approach (RBA) to AML compliance.

This means that we:

• Identify and assess ML/TF risks

• Apply enhanced measures to high-risk Users

• Apply simplified measures to low-risk Users

• Continuously monitor risk levels

Risk factors include:

• Geographic location

• Transaction patterns

• Source of funds

• User behavior

• Product usage

• Wallet interactions

5. Prohibited Users

The following individuals and entities are strictly prohibited from using the Services:

• Residents or citizens of:

  • United States of America

  • Canada

  • Russian Federation

  • Any sanctioned or restricted jurisdiction

• Sanctioned persons or entities

• Politically exposed persons (PEPs) without EDD approval

• Users acting on behalf of restricted or sanctioned parties

Circumventing geo-blocking or KYC controls is strictly prohibited.

6. Customer Due Diligence (CDD)

All Users must complete identity verification before accessing the Services.

CDD includes:

• Full legal name

• Date of birth

• Nationality

• Residential address

• Government-issued photo ID

• Liveness/selfie verification

• Proof of address (if required)

Corporate clients must provide:

• Certificate of incorporation

• Articles of association

• UBO information

• Director details

• Proof of business activities

7. Enhanced Due Diligence (EDD)

EDD is applied to high-risk Users, including:

• Politically Exposed Persons (PEPs)

• High-volume traders

• Users from high-risk jurisdictions

• Users with complex ownership structures

• Users flagged by monitoring systems

EDD measures may include:

• Source of funds verification

• Source of wealth verification

• Additional documentation

• Manual compliance review

• Ongoing monitoring

8. Simplified Due Diligence

Simplified measures may be applied to low-risk Users, subject to internal risk scoring.

This does not remove the obligation to identify the User.

9. Identity Verification

HIKARICP uses automated and manual verification tools to validate identity.

Verification may include:

• Document authenticity checks

• Facial recognition

• Liveness detection

• Cross-database screening

We reserve the right to reject any document at our sole discretion.

10. Source of Funds & Source of Wealth

Users may be required to disclose:

• Origin of deposited crypto assets

• Previous exchange history

• Mining activity

• Salary, business income, inheritance, or investments

Failure to provide satisfactory evidence may result in account suspension or termination.

11. Politically Exposed Persons (PEPs)

A Politically Exposed Person (PEP) is an individual who is or has been entrusted with a prominent public function, including their immediate family members and close associates.

HIKARICP applies Enhanced Due Diligence (EDD) to all PEPs, including:

• Senior government officials

• Politicians

• Judicial officials

• Military officials

• Executives of state-owned enterprises

• Close associates and family members

EDD measures for PEPs include:

• Senior management approval

• Verification of source of funds and wealth

• Continuous transaction monitoring

• Periodic reviews

12. Sanctions Screening

HIKARICP screens all Users against international sanctions lists, including but not limited to:

• UN sanctions lists

• EU consolidated list

• OFAC SDN list

• Other international watchlists

Screening is performed:

• At onboarding

• On an ongoing basis

• Upon material changes in User profiles

If a User matches a sanctions list, their account will be immediately frozen and reported where required.

13. Wallet Screening and Blockchain Analytics

As a custodial exchange, HIKARICP employs blockchain analytics tools to monitor wallet activity.

We screen:

• Deposit addresses

• Withdrawal destinations

• Counterparty wallets

• Transaction histories

High-risk indicators include:

• Darknet markets

• Mixing services

• Privacy protocols

• Sanctioned addresses

• Hacks and exploits

• Scam-related wallets

High-risk wallets may be blocked automatically.

14. Ongoing Monitoring

All User activity is subject to continuous monitoring.

This includes:

• Trading patterns

• Deposit and withdrawal behavior

• Velocity of transactions

• Use of services (spot, futures, staking)

• Unusual account behavior

Monitoring is conducted using both automated systems and manual reviews.

15. Transaction Monitoring

HIKARICP monitors transactions for suspicious activity, including but not limited to:

• Structuring

• Rapid in-and-out movement

• Circular transactions

• Unusual volume spikes

• Pattern anomalies

• Cross-chain obfuscation

Transactions may be delayed, blocked, or reversed for compliance review.

16. Suspicious Activity Reporting (SAR)

If suspicious activity is detected, HIKARICP may:

• Conduct internal investigations

• Request additional information

• Suspend the Account

• File Suspicious Activity Reports (SARs) with relevant authorities where required

Users will not be notified of any SAR filing.

17. Custodial Risk Controls

As a custodial platform, HIKARICP implements additional safeguards:

• Segregation of hot and cold wallets

• Multi-signature storage

• Role-based access controls

• Withdrawal limits

• Behavioral anomaly detection

We reserve the right to freeze assets if risk thresholds are exceeded.

18. Travel Rule Compliance

Where applicable, HIKARICP complies with the FATF Travel Rule.

This may include:

• Collection of sender and recipient information

• Data sharing with other VASPs

• Blocking non-compliant counterparties

19. Record Keeping

HIKARICP maintains records of:

• User identification data

• Transaction records

• Compliance reviews

• SARs

• Communication logs

Records are retained for a minimum of five (5) years or longer if required.

20. Data Retention

Personal data is retained only as long as necessary for:

• Legal compliance

• Risk management

• Dispute resolution

• Regulatory requests

Data may be retained after account closure.

21. Compliance Officer

HIKARICP appoints a designated Compliance Officer responsible for:

• AML program oversight

• Risk assessments

• SAR management

• Regulatory liaison

• Internal reporting

22. Internal Controls

Internal controls include:

• Segregation of duties

• Access restrictions

• Audit trails

• Incident response procedures

• Escalation protocols

23. Staff Training

All relevant personnel receive regular AML training, including:

• Red flags

• Reporting obligations

• System usage

• Regulatory developments

24. Third-Party Providers

Third-party vendors used for KYC, blockchain analytics, or monitoring must meet strict compliance standards.

HIKARICP remains responsible for oversight.

25. Enforcement Measures

Violations of this Policy may result in:

• Account suspension

• Asset freezing

• Account termination

• Confiscation where legally required

• Reporting to authorities

26. Policy Updates

This Policy may be updated at any time.

Continued use of the Platform constitutes acceptance of the revised Policy.

27. Contact

For compliance inquiries contact support.