Anti-Money Laundering Policy

1. Introduction

LevishCoders is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our procedures to detect, prevent, and report suspicious activities that may involve money laundering, terrorist financing, or other financial crimes.

We comply with all applicable laws and regulations, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, EU Anti-Money Laundering Directives, and Financial Action Task Force (FATF) recommendations.

2. Scope

This AML policy applies to:

• All users of the LevishCoders Platform
• All financial transactions processed through the Platform
• Trading activities including cryptocurrency exchanges
• Peer-to-peer transactions and escrow services
• Gift card purchases and redemptions
• All employees, contractors, and partners of LevishCoders

3. Know Your Customer (KYC) Procedures

3.1 Identity Verification

All users must complete identity verification before accessing financial services. Our KYC process includes:

• Basic Verification: Name, email, phone number, date of birth
• Standard Verification: Government-issued photo ID, proof of address
• Enhanced Verification: Additional documentation for high-value transactions, source of funds declaration

3.2 Customer Due Diligence (CDD)

We perform risk-based customer due diligence at account opening and on an ongoing basis. Enhanced due diligence (EDD) is applied to high-risk customers, politically exposed persons (PEPs), and customers from high-risk jurisdictions.

3.3 Ongoing Monitoring

We continuously monitor customer activity to ensure that transactions are consistent with our knowledge of the customer's business, risk profile, and source of funds.

4. Transaction Monitoring

We employ automated and manual transaction monitoring systems to detect suspicious activities:

• Real-time transaction screening against sanctions lists
• Pattern recognition for unusual transaction volumes or frequencies
• Detection of structuring attempts (breaking large transactions into smaller ones)
• Monitoring for rapid movement of funds across accounts
• Flagging transactions involving high-risk jurisdictions
• AI-powered anomaly detection systems

5. Suspicious Activity Reporting

When suspicious activity is detected, we:

• File Suspicious Activity Reports (SARs) with the appropriate financial intelligence unit
• Cooperate fully with law enforcement investigations
• Preserve all records related to suspicious activity
• Do not disclose to the subject that a report has been filed (tipping-off prohibition)

Users who suspect fraudulent activity should report it immediately to compliance@levishcoders.com.

6. Sanctions Screening

We screen all users and transactions against major sanctions lists including:

• OFAC (Office of Foreign Assets Control) SDN List
• EU Consolidated Sanctions List
• UK HM Treasury Sanctions List
• UN Security Council Sanctions List

Users from sanctioned countries or individuals on sanctions lists are prohibited from using the Platform.

7. Record Keeping

We maintain comprehensive records of all customer identification documents, transaction records, and AML-related correspondence for a minimum of five (5) years after the end of the business relationship, in accordance with applicable regulations.

8. Staff Training

All LevishCoders employees receive regular AML/CTF training covering:

• Identification of suspicious activities and red flags
• KYC and CDD procedures
• Reporting obligations and procedures
• Updates to AML regulations and best practices
• Consequences of non-compliance

9. Enforcement

Violations of this AML policy may result in:

• Immediate account suspension or termination
• Freezing of funds pending investigation
• Reporting to law enforcement authorities
• Civil or criminal penalties as applicable

10. Policy Updates

This policy is reviewed and updated at least annually, or more frequently as required by changes in regulations or business operations. Users will be notified of material changes through the Platform.

For questions about this AML policy, contact our compliance team at compliance@levishcoders.com.