DGN AML/KYC Policy

• Business Company No. 2173379
• Rough Point, P.O. Box 4203
• Mount Healthy, Road Town
• Tortola, VG1110, British Virgin Islands
• Website: www.d-gn.io
• AML Compliance Officer: compliance@d-gn.io

• Financial Action Task Force (FATF) recommendations
• Bank Secrecy Act (BSA) requirements where applicable
• EU Anti-Money Laundering Directives for European users
• Local jurisdiction requirements in user domicile countries
• International sanctions and embargo restrictions

• Assesses individual user risk profiles
• Implements enhanced due diligence for high-risk users
• Monitors transactions and patterns for suspicious activity
• Applies appropriate controls based on assessed risk levels

All users must provide accurate identification information:

• Full legal name as it appears on government identification
• Date of birth and age verification
• Residential address with proof of residence
• Email address and contact information
• Nationality and country of residence
• Government-issued photo identification (passport, national ID, driver's license) [Enhanced]
• Proof of address (utility bill, bank statement, government document) [Enhanced]
• Selfie photograph for identity verification [Enhanced]
• Additional documentation as required by risk assessment [Enhanced]

• Automated Document Verification: Using AI-powered identity verification services
• Biometric Matching: Facial recognition comparing selfies to ID documents
• Address Verification: Cross-referencing provided addresses with authoritative databases
• Sanctions Screening: Real-time checking against global sanctions lists
• Politically Exposed Person (PEP) Screening: Enhanced due diligence for high-risk individuals

• Changes in risk profile indicators
• Unusual transaction patterns or behaviors
• Updates to sanctions and watchlists
• Material changes in personal circumstances

• High-Value Participants: Users receiving cumulative rewards exceeding $2,000
• Politically Exposed Persons (PEPs): Government officials, senior executives, immediate family members
• High-Risk Jurisdictions: Users from countries with elevated money laundering risks
• Complex Ownership Structures: Corporate or entity accounts with unclear beneficial ownership
• Unusual Activity Patterns: Users exhibiting suspicious submission or reward patterns

• Source of Funds Documentation: Evidence of legitimate income sources
• Beneficial Ownership Information: For corporate or trust accounts
• Enhanced Address Verification: Additional proof of residence documentation
• Professional References: Business or professional relationship confirmations
• Detailed Background Information: Employment history and business activities

• Increased Transaction Scrutiny: More frequent review of account activity
• Periodic Information Updates: Regular confirmation of user information
• Third-Party Intelligence: Additional due diligence research and verification
• Senior Management Review: Approval requirements for high-risk account activities

• Unusual Submission Patterns: Abnormal frequency, timing, or quality of data submissions
• Reward Concentration: Disproportionate reward accumulation relative to typical users
• Geographic Anomalies: Access patterns inconsistent with declared residence
• Device and IP Inconsistencies: Multiple accounts from single devices or IP addresses
• Behavioral Patterns: Activity inconsistent with stated user profile

• Multiple accounts with identical or similar submission patterns
• Rapid accumulation of rewards followed by immediate withdrawal attempts
• Use of VPNs or proxy servers to mask geographic location
• Provision of false or fraudulent identification documents
• Attempts to circumvent platform security measures or submission limits
• Connections to known sanctioned individuals or entities

• Immediate Review: Automated flagging for manual investigation
• Account Restrictions: Temporary suspension of rewards or account access
• Information Gathering: Request for additional documentation or explanation
• Law Enforcement Cooperation: Reporting to appropriate authorities when required
• Decision Documentation: Detailed records of investigation and conclusions

• Office of Foreign Assets Control (OFAC) sanctions lists
• United Nations Security Council consolidated list
• European Union sanctions and restrictive measures
• UK HM Treasury financial sanctions lists
• Other Relevant Jurisdictions as applicable to our operations

• OFAC-Sanctioned Countries: Currently including Iran, North Korea, Syria, and Crimea region
• FATF High-Risk Jurisdictions: Countries with strategic AML/CFT deficiencies
• Comprehensively Sanctioned Territories: As updated by relevant authorities
• Embargoed Regions: Subject to comprehensive trade restrictions

• Pre-Registration Screening: Verification before account creation
• Ongoing Monitoring: Regular re-screening of existing users
• Transaction Blocking: Immediate suspension of prohibited transactions
• Asset Freezing: Compliance with asset freeze requirements
• Reporting Obligations: Notification to relevant authorities as required

• Customer Identification Records: 7 years from account closure
• Transaction Records: 7 years from transaction date
• Suspicious Activity Reports: 7 years from filing date
• Sanctions Screening Results: 7 years from screening date
• Investigation Documentation: 7 years from case closure

• Timely Retrieval: Available within 5 business days upon request
• Regulatory Access: Available to authorized government agencies
• Data Integrity: Protected against unauthorized modification
• Confidentiality: Accessible only to authorized personnel
• Backup and Recovery: Maintained in multiple secure locations

• Transactions appear designed to evade reporting requirements
• Activities suggest money laundering or terrorist financing
• Users provide false or suspicious identification
• Patterns indicate coordination between multiple accounts
• Other circumstances suggest criminal activity

• Single transactions exceed applicable thresholds
• Multiple related transactions exceed thresholds
• Structured transactions appear designed to avoid reporting
• Cash equivalent transactions meet reporting criteria

• Financial Intelligence Unit (FIU) reporting in relevant jurisdictions
• Cross-border transaction reporting where required
• Beneficial ownership reporting for corporate accounts
• Wire transfer information sharing under Travel Rule requirements

• AML/KYC Regulations: Current legal and regulatory requirements
• Red Flag Recognition: Identifying suspicious activities and behaviors
• Investigation Procedures: Proper escalation and documentation practices
• Sanctions Compliance: Current restrictions and screening requirements
• Record Keeping: Documentation and retention requirements

• Annual Training Updates: Refresher training on current requirements
• Regulatory Updates: Notification of changes in applicable laws
• Best Practices Sharing: Industry guidance and lessons learned
• Performance Monitoring: Regular assessment of compliance effectiveness

• Provide accurate and complete information during registration
• Update information promptly when circumstances change
• Respond to requests for additional documentation in a timely manner
• Report suspected fraudulent activity or account compromise
• Comply with applicable laws in their jurisdiction

• Create multiple accounts to circumvent limits or controls
• Provide false or fraudulent identification documents
• Use the platform for money laundering or terrorist financing
• Attempt to circumvent sanctions or embargo restrictions
• Engage in activities designed to evade detection or reporting

• Verification Requests: Providing requested documentation promptly
• Investigation Inquiries: Responding to questions about account activity
• Legal Process: Complying with lawful requests from authorities
• Platform Security: Following security guidelines and procedures

• Account Suspension: Temporary restriction of platform access
• Account Termination: Permanent closure of user account
• Reward Forfeiture: Loss of accumulated points or pending rewards
• Transaction Blocking: Prevention of specific transactions or activities

• Suspicious Activity Reporting: Filing of SAR with appropriate authorities
• Law Enforcement Notification: Direct reporting to investigative agencies
• Regulatory Reporting: Notification to relevant financial supervisors
• Criminal Referral: Cooperation with law enforcement investigations

• Access Controls: Limiting access to authorized personnel only
• Encryption: Securing data in transit and at rest
• Audit Trails: Maintaining logs of access and modifications
• Confidentiality Agreements: Binding all staff to confidentiality requirements

• Regulatory Authorities: As required by law or regulation
• Law Enforcement: Upon lawful request or court order
• Service Providers: Under strict confidentiality agreements
• Legal Representatives: For compliance and legal advice purposes

• Regulatory Changes: New laws and regulations
• Industry Best Practices: Evolving compliance standards
• Risk Assessment Updates: Changes in risk environment
• Technology Improvements: Enhanced monitoring and verification capabilities

• Email Notification: Direct communication to registered users
• Platform Notices: Prominent website and application notifications
• Terms Updates: Incorporation into updated Terms and Conditions
• Policy Publication: Updated documentation on company website

• Email: compliance@d-gn.io
• Subject: 'AML/KYC Inquiry'
• Response Time: 5 business days for standard inquiries

• Email: verification@d-gn.io
• Subject: 'KYC Documentation - [Your Username]'
• Encryption: Available for sensitive document transmission

• Email: suspicious@d-gn.io
• Subject: 'Suspicious Activity Report'
• Confidentiality: All reports treated with strict confidentiality

• Data Guardian Tech Ltd.
• Attention: AML/KYC Compliance Officer
• Rough Point, P.O. Box 4203
• Mount Healthy, Road Town
• Tortola, VG1110, British Virgin Islands

• Financial Intelligence Units: In jurisdictions where we operate
• Banking Regulators: For oversight and compliance guidance
• Law Enforcement Agencies: For investigation support when required
• International Organizations: For best practice sharing and coordination

• Regulatory Examinations: On-site and off-site reviews
• Compliance Audits: Internal and external compliance assessments
• Investigation Support: Assistance with law enforcement inquiries
• Document Production: Timely provision of requested records