Anti-Money Laundering (AML) Policy

1. Introduction & Commitment

InfinityBlockchain LLC (“Company”) is committed to the highest standards of anti-money laundering (AML) compliance and combating the financing of terrorism (CFT). We take our legal and ethical obligations seriously and are dedicated to preventing the use of our Platform for illicit purposes.

This policy is designed to comply with applicable US federal AML laws, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, and guidelines issued by the Financial Crimes Enforcement Network (FinCEN).

This policy applies to all users, affiliates, and transactions processed through the Platform.

2. Scope

This policy covers:

• All transactions processed through the Platform, including purchases and commission payouts
• Card payments processed via Stripe (which maintains its own PCI DSS and AML compliance programs)
• Cryptocurrency payments via CoinPayments (USDC and other supported cryptocurrencies)
• Commission payouts via bank transfer (IBAN/BIC) or cryptocurrency wallet
• User registration, KYC verification, and ongoing account monitoring

3. Know Your Customer (KYC)

KYC verification may be required under the following circumstances:

• Payout requests above certain value thresholds
• Detection of suspicious or unusual account activity
• Regulatory requirements applicable to the user’s jurisdiction
• High-risk transaction patterns or account profiles

4. Customer Due Diligence (CDD)

5. Transaction Monitoring

We monitor transactions and account activity for indicators of potential money laundering or other suspicious activity, including:

• Unusual referral patterns (e.g., circular referral structures, self-referrals)
• Rapid creation of multiple accounts from similar identifiers
• Suspicious payout requests (unusual amounts, frequency, or destinations)
• Sudden large commission earnings without organic referral growth
• Use of multiple payment methods or wallets without clear business purpose

The Company reserves the right to freeze accounts and withhold payouts pending investigation when suspicious activity is detected.

6. Suspicious Activity Reporting

• Suspicious Activity Reports (SARs) are filed with FinCEN as required by applicable law.
• In accordance with the “tipping off” prohibition, the Company will not inform users if a SAR has been filed regarding their account or transactions.
• All personnel with access to transaction data are trained to recognize and escalate suspicious activity indicators.

7. Prohibited Activities

The following activities are strictly prohibited on the Platform:

• Using the Platform to launder money or finance terrorism
• Creating fake referral networks to generate artificial commissions
• Using stolen, forged, or unauthorized payment methods
• Structuring transactions to avoid reporting thresholds or detection
• Accessing or using the Platform from OFAC-sanctioned countries or territories
• Concealing the source, ownership, or destination of funds
• Providing false or misleading identity information
• Operating on behalf of undisclosed third parties

8. Sanctions Compliance

• The Company complies with sanctions programs administered by the U.S. Office of Foreign Assets Control (OFAC).
• Users located in or acting on behalf of individuals or entities in sanctioned countries or territories are prohibited from using the Platform.
• Screening of users against OFAC sanctions lists (SDN List, Consolidated Sanctions List) may be conducted as part of our due diligence process.

9. Record Keeping

• Transaction records are maintained for a minimum of 5 years from the date of the transaction, or longer as required by applicable law.
• KYC documents and identity verification records are stored securely with appropriate access controls.
• All records are available to regulatory and law enforcement authorities upon lawful request (subpoena, court order, or regulatory inquiry).

10. Cryptocurrency-Specific Measures

• USDC (a USD-pegged stablecoin) is the primary cryptocurrency used on the Platform, minimizing value fluctuation risks.
• Cryptocurrency wallet addresses are recorded and linked to user accounts for all payout transactions.
• Blockchain analysis tools may be utilized to assess wallet risk scores and transaction histories where warranted.
• Payouts are only processed to wallet addresses registered in the user’s verified account profile.

11. Cooperation with Authorities

InfinityBlockchain LLC is committed to full cooperation with law enforcement and regulatory authorities:

• We respond to lawful subpoenas, court orders, and regulatory information requests in a timely manner.
• We report suspicious activity to FinCEN as required by the Bank Secrecy Act.
• We preserve records and evidence when notified of an investigation or legal proceeding.

12. Policy Enforcement

Violations of this AML Policy may result in one or more of the following actions, at the Company’s sole discretion:

• Immediate account suspension pending investigation
• Permanent account termination
• Forfeiture of all pending commissions and wallet balances
• Reporting of suspicious activity to FinCEN and/or law enforcement
• Pursuit of legal remedies available under applicable law

13. Changes to This Policy

This AML Policy is reviewed and updated periodically to reflect changes in regulatory requirements, industry best practices, and our operational procedures. Updated versions will be published on this page with a revised effective date.