Anti-Money-Laundering Policy

Notice. This page describes our AML posture in general terms for the public. It is not legal advice and is not a substitute for the internal AML Program, which is treated as confidential and made available to regulators and auditors on request.

\u00a7 1. Scope and framework

Our AML Program is designed to satisfy the United States Bank Secrecy Act (BSA) as implemented by FinCEN, the USA PATRIOT Act, applicable state money-transmission statutes, and, on attaining regulatory status, the SEC and CFTC equivalents. Where customers or counterparties are subject to EU, UK, or other AML regimes, we align controls to the stricter standard.

The Program is approved by the Board and reviewed at least annually, or more frequently in response to regulatory change, enforcement action, or material growth in risk.

\u00a7 2. Governance

\u00a7 3. Customer Identification Program (CIP)

We collect and verify identity information for every Member, beneficial owner, and authorised signatory at admission, and refresh it periodically. CIP elements include legal name, date of birth or formation, physical address, and a government-issued identification number. Verification uses documentary and non-documentary methods, including identity-verification providers and public registry checks.

\u00a7 4. Customer Due Diligence (CDD)

Beyond CIP, we conduct risk-based CDD to understand the nature and purpose of the Member’s relationship with Wavestar. CDD includes ownership and control structure, source of funds, anticipated activity, and geographic footprint. A risk rating is assigned at admission and refreshed annually or on trigger events.

\u00a7 5. Enhanced Due Diligence (EDD)

EDD applies to higher-risk relationships, including Politically Exposed Persons (PEPs) and their close associates, customers domiciled in higher-risk jurisdictions, customers with complex ownership structures, and customers engaged in higher-risk resource classes. EDD measures include enhanced source-of-funds and source-of-wealth enquiries, senior management approval, and increased transaction monitoring.

\u00a7 6. Sanctions

We screen Members, beneficial owners, and counterparties against the consolidated sanctions lists administered by the U.S. Office of Foreign Assets Control (OFAC), the United Nations, the European Union, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI), and other relevant authorities, at admission and on an ongoing basis. Matches are escalated to the AML Officer for adjudication. Prohibited transactions are blocked or rejected as the law requires.

\u00a7 7. Transaction monitoring

Cleared activity is monitored automatically for patterns suggestive of money laundering, terrorist financing, sanctions evasion, structuring, market manipulation, or other financial crime. Rule-based scenarios run in near real time; model-based scoring runs daily. Alerts are triaged by the AML team using a documented workflow, with outcomes recorded in our case-management system.

\u00a7 8. Reporting

\u00a7 9. Recordkeeping

We retain AML records for not less than five years, and longer where a records preservation obligation applies. Records include CIP evidence, CDD/EDD files, transaction histories, monitoring alerts and their disposition, SAR narratives (with strict access controls), and sanctions screening results.

\u00a7 10. Training

All staff complete AML training annually; higher-exposure roles complete additional role-specific training. Training is updated when law, typologies, or our product set changes.

\u00a7 11. Regulator and law-enforcement requests

We respond to lawful regulator and law-enforcement requests promptly. The Chief Compliance Officer and, for regulator matters of material significance, the Board Risk Committee, are notified of material requests.