Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

FibWealth (“Company,” “we,” “us,” or “our”) enforces a comprehensive, zero-tolerance Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) framework designed in strict accordance with international standards and statutory mandates.

Our compliance infrastructure is aligned with the following global legal standards:

• Financial Action Task Force (FATF) Recommendations: Specifically Recommendation 16 (the "Travel Rule") and guidance for Virtual Asset Service Providers (VASPs).
• European Union Directives: Directive (EU) 2018/843 (5AMLD) and Directive (EU) 2018/1673 (6AMLD) on combating money laundering and terrorist financing.
• International Sanctions Regimes: United Nations Security Council (UNSC), US Office of Foreign Assets Control (OFAC), UK HM Treasury (HMT), and European Union consolidated sanctions lists.
• USA PATRIOT Act & Bank Secrecy Act (BSA) Principles: Applied as international best practices for risk mitigation, customer due diligence, and transaction record-keeping.

All users, institutional allocators, and partners accessing fibwealth.com must undergo identity verification and ongoing transaction scrutiny as a prerequisite to utilizing our platform services.

FibWealth employs an automated and continuous Risk-Based Approach (RBA) to evaluate, categorize, and mitigate financial crime risks across all accounts and digital asset transactions:

To prevent identity theft, fraudulent registrations, and unauthorized platform access, FibWealth enforces a multi-tier Customer Identification Program.

3.1. Individual Allocator Verification (Tier 1 & Tier 2)

• Primary Government Photo Identification: A clear, unexpired, machine-readable passport, national identity card, or driver's license containing the user's full legal name, date of birth, document number, and signature.
• Proof of Residential Address (PoA): A certified bank statement, municipal tax notice, or utility bill (water, gas, electricity) issued within the preceding ninety (90) days displaying the user's registered physical address.
• Biometric Liveness & Facial Geometry Check: Real-time 3D facial recognition to establish that the registrant is physically present and matches the submitted photo credentials.

3.2. Corporate & Institutional Due Diligence (Tier 3)

Institutional and corporate accounts must provide comprehensive documentation before onboarding:

• Certified Certificate of Incorporation, Memorandum, and Articles of Association.
• Register of Directors and Ultimate Beneficial Owners (UBO) holding 10% or more equity or voting rights.
• Proof of identity and address for all authorized account signatories and executive directors.
• Corporate Resolution authorizing the opening and operation of the FibWealth account.

Before activating any account and continuously throughout the business relationship, FibWealth runs automated checks against global intelligence databases:

• Sanctions Screening: All account holders are screened against global databases including OFAC Specially Designated Nationals (SDN), UN Sanctions Committees, EU Financial Sanctions, and UK HMT lists. Accounts associated with designated individuals or entities are immediately blocked.
• Politically Exposed Persons (PEPs): Individuals entrusted with prominent public functions (and their immediate family members and close associates) are classified as PEPs and subject to mandatory Enhanced Due Diligence (EDD) and continuous senior compliance oversight.
• Adverse Media & Regulatory Enforcement Checks: Automated scanning across global law enforcement databases, financial crime registries, and global media for involvement in financial fraud, corruption, or cybercrime.

To ensure that all deployed capital originates from legitimate commercial, professional, or investment activities, FibWealth implements multi-layered provenance verifications:

• Source of Funds (SoF) Inquiries: FibWealth reserves the right to request proof of income, certified tax filings, audited financial statements, or cryptographic proof of initial asset acquisition.
• On-Chain Blockchain Intelligence: Every cryptocurrency deposit and destination withdrawal address is processed through institutional blockchain forensics (screening against high-risk clusters, darknet marketplaces, ransomware addresses, sanctioned protocols, and mixing/tumbling services like Tornado Cash).
• Tainted Asset Rejection: Deposits originating from mixing services, high-risk non-compliant exchanges, or compromised contracts are automatically quarantined and rejected.

FibWealth strictly prohibits any attempt to utilize our platform infrastructure for illicit or manipulative practices:

• Smurfing and Structuring: Splitting deposits or withdrawals into smaller increments to evade KYC verification thresholds or regulatory reporting triggers is strictly prohibited.
• Multi-Accounting & Referral Farming: Operating multiple profiles by a single legal person to exploit promotional deposit matching bonuses or farm affiliate commissions violates platform integrity and triggers instant asset forfeiture.
• Third-Party Payments: All external funding deposits and withdrawal destinations must correspond directly to the legal name registered on the verified FibWealth account. Third-party deposits or third-party withdrawal routing are strictly rejected.
• Jurisdictional Restrictions: FibWealth does not provide services to residents or citizens of jurisdictions subject to comprehensive international sanctions or FATF blacklist/greylist designations (e.g., North Korea, Iran, Syria, Cuba, Crimea, and related non-cooperative territories).

Pursuant to international AML statutes:

• Automated Surveillance: Our systems continuously monitor transaction velocities, anomalous withdrawal requests, geographic inconsistencies, and rapid changes in account behavior.
• Filing of Suspicious Activity Reports (SARs): Where reasonable grounds exist to suspect that funds are derived from illegal activity or intended for unlawful conduct, FibWealth will generate and transmit a Suspicious Activity Report (SAR) / Suspicious Transaction Report (STR) to the competent Financial Intelligence Unit (FIU) or law enforcement authority.
• Statutory Prohibition Against Tipping-Off: Under international law (including UK Proceeds of Crime Act and EU Directives), FibWealth and its personnel are strictly prohibited from disclosing to the customer or any third party that a suspicious activity investigation, SAR, or regulatory inquiry has been initiated.

In compliance with FATF Recommendation 11 and EU 5AMLD:

• Five-to-Seven Year Mandatory Retention: All customer identification records, verification documents, transaction files, and compliance notes are preserved for a mandatory minimum of five (5) to seven (7) years following the termination of the account relationship.
• Immutable Double-Entry Ledger: All deposits, bonus allocations, investment activations, daily yield distributions, and withdrawal executions are logged immutably on our append-only double-entry ledger. Financial records cannot be altered, overwritten, or deleted.
• Audit Trail Integration: Administrative reviews, KYC approvals, rejections, and security state changes record complete audit fields (actor_id, action, target_entity, before_state, after_state, reason, and timestamp) for full regulatory auditability.

The FibWealth compliance division operates independently to enforce this Policy, conduct periodic risk assessments, and interact with global regulatory bodies.

• Investor Support: Submit inquiries or identity documentation updates directly through the KYC / Security category within the authenticated Investor Portal.
• Compliance Office: For official legal, regulatory, or institutional inquiries, contact our compliance team at compliance@fibwealth.com or aml@fibwealth.com.