Interchained ("Company") is committed to maintaining the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This AML Policy outlines the measures we implement to prevent the iFUND Protocol platform from being used for illicit purposes.

This policy applies to all users, employees, contractors, and third-party service providers associated with the Platform.

Our AML program is designed to comply with:

• Financial Action Task Force (FATF) Recommendations
• Applicable national and international AML/CTF laws
• Cryptocurrency-specific regulatory guidance
• Sanctions programs (OFAC, UN, EU, and other applicable lists)

We continuously monitor regulatory developments and update our policies accordingly.

Customer Identification Program (CIP):

We implement a risk-based approach to customer identification:

• Basic Verification: Email verification and wallet address validation for standard users
• Enhanced Verification: Government ID, proof of address, and selfie verification for:
  • Project creators (mandatory KYC)
  • High-value transactions exceeding thresholds
  • Users flagged by risk monitoring systems
• Ongoing Monitoring: Continuous review of user activity and periodic re-verification

Information Collected:

• Full legal name
• Date of birth
• Nationality and country of residence
• Government-issued identification document
• Proof of address (utility bill, bank statement)
• Source of funds (for high-risk users)

We employ automated and manual monitoring systems to detect suspicious activity:

• Real-time Monitoring: Automated screening of all transactions
• Pattern Analysis: Detection of unusual transaction patterns, structuring, or layering
• Velocity Checks: Monitoring for rapid, high-frequency transactions
• Blockchain Analytics: Integration with blockchain analysis tools to trace fund origins and destinations
• Sanctions Screening: Continuous screening against global sanctions lists

Red Flags We Monitor:

• Transactions with no apparent economic purpose
• Unusual transaction sizes or frequencies
• Connections to high-risk jurisdictions
• Use of mixing services or privacy coins for obfuscation
• Multiple accounts linked to the same identity
• Reluctance to provide requested documentation

We classify users and transactions based on risk levels:

Enhanced due diligence (EDD) is applied to high-risk users, including additional documentation requirements and more frequent monitoring.

Prohibited Activities:

• Money laundering or terrorist financing
• Fraud, scams, or Ponzi schemes
• Tax evasion or sanctions violations
• Drug trafficking or weapons dealing
• Human trafficking or exploitation
• Any activity violating applicable laws

Restricted Jurisdictions:

Users from the following jurisdictions are prohibited from using the Platform:

• Countries subject to comprehensive sanctions (e.g., North Korea, Iran)
• Jurisdictions designated as high-risk by FATF
• Any jurisdiction where cryptocurrency services are prohibited

When suspicious activity is detected, we:

• Investigate: Conduct internal investigation and gather relevant information
• Freeze: Temporarily suspend account activity if warranted
• Report: File Suspicious Activity Reports (SARs) with relevant authorities as required
• Cooperate: Provide information to law enforcement upon valid legal request

Users are prohibited from being informed that a SAR has been filed ("tipping off" prohibition).

Accounts may be frozen when:

• Suspicious activity is detected
• Required by law enforcement or regulatory order
• User fails to provide requested KYC documentation
• Sanctions screening returns a positive match
• Fraud or policy violations are suspected

Frozen accounts retain the ability to receive incoming funds but outgoing transfers are blocked pending investigation. Users will be notified of freezes to the extent permitted by law.

We maintain comprehensive records including:

• Customer identification documents and verification records
• Transaction records and blockchain data
• Risk assessments and due diligence documentation
• SAR filings and investigation records
• Training records for compliance personnel

Records are retained for a minimum of 5 years after account closure or last transaction, or longer if required by applicable regulations.

Our AML compliance program includes:

• Designated Compliance Officer: Responsible for AML program oversight
• Written Policies: Documented procedures for all AML processes
• Training: Regular training for all relevant personnel
• Independent Testing: Periodic audits of AML controls
• Technology: Automated monitoring and screening systems

By using the Platform, users agree to:

• Provide accurate and truthful identification information
• Promptly respond to requests for additional documentation
• Not use the Platform for any prohibited purpose
• Report any suspected money laundering or illegal activity
• Comply with all applicable laws and regulations

To report suspicious activity or for AML-related inquiries: