1. Information Collection
The Issuer and service providers may collect identity, residency, corporate ownership, source-of-funds, source-of-wealth, wallet, transaction, and supporting compliance documentation.
2. Screening and Analytics
Compliance workflows may include sanctions lists, PEP screening, adverse media, wallet risk scoring, blockchain analytics, and anti-fraud signals.
3. Enhanced Due Diligence
Enhanced due diligence may be applied for complex ownership structures, high-risk geographies, unusual wallet activity, high-value transactions, or suspicious patterns.
4. Refusal, Suspension, Freezing, and Reporting
Where legally required or operationally necessary, the Issuer may reject applications, delay settlement, freeze allocations, terminate participation, or file reports with competent authorities.
5. No Tolerance for Evasion
Stolen identity use, forged records, straw purchasers, false residency declarations, and wallet obfuscation designed to evade monitoring may trigger immediate rejection.
6. Record Retention
Compliance records may be retained for periods required by law or legitimate compliance needs, including AML, sanctions, tax, and dispute/litigation obligations.
7. Ongoing Monitoring
Participation may remain subject to post-sale monitoring, supplemental document requests, and re-verification checks where risks change over time.