> For the complete documentation index, see [llms.txt](https://docs.visionmakers.io/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.visionmakers.io/legal/aml-kyc.md).

# 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.

<div class="callout">
<span class="callout-label">Scope and specialist review</span>
Vision Makers operates a <strong>non-custodial</strong> software interface and does not take
custody, exchange fiat, or act as a money transmitter. Whether, and where, the platform
constitutes a regulated Virtual Asset Service Provider is a jurisdiction-specific legal question
that must be <strong>confirmed by counsel</strong>. This programme is written to meet FATF-aligned
standards on a risk-sensitive basis; registration or licensing obligations identified by counsel
must be completed before operating in the relevant jurisdiction.
</div>

## 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](/platform/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](/legal/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](/legal/travel-rule).

## 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](/legal/privacy).

## 10 · Your obligations

You must provide accurate, current information; not use the Service for any purpose in this
Policy or the [Acceptable Use Policy](/legal/acceptable-use); not act for an undisclosed third
party; and respond to reasonable information requests. Failure may result in restriction or
termination.

## Contact

[admin@visionmakers.io](mailto:admin@visionmakers.io)