AML, CTF and KYC Policy
Version 2.0 · Effective 24 October 2026
This Policy describes how Vision Makers Technologies Inc. counters money laundering, terrorist financing and proliferation financing.
1 · Commitment
We prohibit the use of the Service for money laundering, terrorist financing, proliferation financing, sanctions evasion and the handling of criminal proceeds, and we cooperate with competent authorities.
2 · Governance
| Element | Position |
|---|---|
| Senior management responsibility | Board-level owner accountable for the programme |
| Compliance officer | MLRO to be appointed and named |
| Independent review | Periodic independent testing of the programme |
| Staff training | At onboarding and at least annually |
| Record keeping | 5 years minimum from end of relationship |
3 · Risk-based approach
We maintain a documented business-wide risk assessment covering customer, geographic, product, delivery-channel and transaction risk, reviewed at least annually and on material change. Controls are proportionate to assessed risk.
Higher-risk indicators include: connection to a high-risk or monitored jurisdiction; politically exposed person status; wallet exposure to mixers, darknet markets, sanctioned addresses, ransomware or stolen funds; structuring behaviour; and inconsistency between stated purpose and observed activity.
4 · Customer due diligence
Where KYC applies. Identity verification is required for Vision Makers Pad launch participation, and may be required for elevated service tiers, on reaching risk-based thresholds, where a transaction or pattern triggers review, or where law requires it.
Standard CDD collects: full legal name, date of birth, nationality, residential address, a government-issued photographic identity document, a liveness/selfie comparison, and the wallet address(es) to be used.
Enhanced due diligence applies to higher-risk customers and adds source of funds and source of wealth evidence, purpose of relationship, senior management approval, and increased ongoing monitoring.
Simplified due diligence may apply to demonstrably low-risk, low-value activity where permitted.
We do not accept anonymous or fictitious-name accounts, and we may refuse or terminate a relationship where CDD cannot be completed.
5 · Screening
All verified customers are screened at onboarding and on an ongoing basis against sanctions lists, PEP and adverse-media datasets. Wallet addresses are screened using blockchain analytics for exposure to illicit sources. See Sanctions.
6 · Ongoing monitoring
Activity is monitored for patterns inconsistent with the customer's profile, structuring, unusual velocity or volume, exposure to high-risk counterparties, and use of obfuscation techniques. Alerts are investigated and documented, and outcomes recorded regardless of whether a report is filed.
7 · Reporting
Where suspicion of money laundering or terrorist financing arises, a Suspicious Activity / Transaction Report is filed with the relevant Financial Intelligence Unit within the statutory deadline.
Tipping off is prohibited. Staff must not disclose to a customer, or any third party, that a report has been or may be made. Where a report is filed, a customer may be restricted without a reason being given.
8 · Travel Rule
Originator and beneficiary information requirements are addressed in the Travel Rule Policy.
9 · Record keeping
Identification evidence, verification results, screening records, transaction records, internal investigations and reports are retained for five years from the end of the relationship, or longer where local law requires. See Privacy Policy §8.
10 · Your obligations
You must provide accurate, current information; not use the Service for any purpose in this Policy or the Acceptable Use Policy; not act for an undisclosed third party; and respond to reasonable information requests. Failure may result in restriction or termination.
Contact
Last updated