Anti-Money Laundering & KYC Policy

1. Policy Overview

Strategirise LLC (Michigan Entity ID: 803262402, EIN: 99-4604269) maintains strict Anti-Money Laundering (AML) and Know Your Customer (KYC) protocols to ensure full compliance with the Bank Secrecy Act (BSA), the USA PATRIOT Act, and all applicable federal, state, and international regulations governing financial transactions and the prevention of money laundering.

This policy establishes our commitment to preventing our services from being used to facilitate money laundering, terrorist financing, fraud, or other illicit financial activities.

2. Know Your Customer (KYC) Requirements

2.1 Client Verification Process

Before engaging in a service agreement with Strategirise LLC, all clients undergo a comprehensive KYC verification process designed to verify the legitimacy of the business entity and the source of funds used for media spending and service payments.

Our KYC requirements include, but are not limited to:

• Business registration and incorporation documents
• Proof of business address and operations
• Identification verification of ultimate beneficial owners (UBO)
• Tax identification numbers (EIN, ITIN, or equivalent)
• Business purpose and nature of services requested
• Source of funds verification for advertising budgets

2.2 Ongoing Customer Due Diligence (CDD)

We maintain updated customer information and conduct periodic reviews to ensure that our clients remain in compliance with applicable regulations and that their business operations have not changed materially. Any significant changes in client operations or unexplained activity patterns trigger enhanced due diligence procedures.

3. Enhanced Due Diligence (EDD)

For high-risk clients, we implement Enhanced Due Diligence (EDD) procedures, including:

• Comprehensive background checks on beneficial owners
• Verification of source of wealth and funds
• Screening against governmental sanctions and watchlists (OFAC, UN, EU sanctions lists)
• Investigation of business purpose and payment flows
• Increased monitoring of transaction patterns and activity
• Documentation of risk assessment rationale

We classify clients as high-risk based on factors including: jurisdiction of operations, industry sector, transaction volume, geographic locations involved in transactions, and any publicly available negative information.

4. Source of Funds Verification

Strategirise LLC maintains strict protocols to verify the source of all advertising budgets and service payments. We require clients to provide documentation demonstrating that funds used for digital advertising campaigns are derived from legitimate business operations.

Acceptable documentation includes:

• Bank statements showing business operations and fund source
• Tax returns and financial statements
• Invoices and proof of sales/revenue generation
• Documentation of loans or investments (with source verification)
• Government-issued identification for fund sources

We reject service engagements where the source of funds cannot be adequately verified or where patterns suggest potential illicit origins.

5. Prohibited Activities and Red Flags

5.1 Prohibited Client Categories

We do not provide services to:

• Individuals or entities on OFAC sanctions lists
• Individuals or entities engaged in prohibited financial activities
• Businesses involved in illegal activities (drug trafficking, weapons trafficking, human trafficking, fraud)
• Entities facilitating terrorism or terrorist financing
• Entities engaged in sanctions evasion
• Individuals or companies on UN or international sanctions lists

5.2 Transaction Red Flags

We monitor for and investigate suspicious transaction patterns, including:

• Unusual transaction sizes or frequencies inconsistent with stated business
• Multiple transactions to high-risk jurisdictions
• Structuring patterns designed to evade reporting thresholds
• Unexplained changes in business operations or fund sources
• Discrepancies between stated business purpose and actual spending patterns
• Rapid movement of funds in and out of accounts
• Use of shell companies or complex ownership structures

5.3 Response to Red Flags

When we identify suspicious activity or red flags, we conduct immediate investigation and may take actions including: suspending service, freezing accounts, conducting enhanced due diligence, or terminating the client relationship. We may also file Suspicious Activity Reports (SARs) as required by law.

6. Managed E-Commerce Platform Monitoring

For clients operating e-commerce platforms where we manage advertising and payment infrastructure, we implement enhanced monitoring including:

• Review of product listings and merchant operations
• Verification that products and services are legal in relevant jurisdictions
• Monitoring of payment flows and transaction patterns
• Screening of high-risk product categories (cryptocurrencies, pharmaceuticals, restricted items)
• Verification of customer base and geographic distribution

We terminate service relationships with merchants engaged in illegal product sales or suspicious business practices.

7. Blockchain & Cryptocurrency Compliance

For clients in Web3, cryptocurrency, and NFT spaces, we implement additional AML/KYC protocols in compliance with FinCEN guidance and international blockchain AML standards.

Requirements include:

• Verification of legal status in relevant jurisdictions
• Proof of compliance with Money Transmitter requirements
• KYC documentation for token holders and transaction participants
• Blockchain address verification and monitoring
• Screening for association with known illicit accounts

8. Sanctions Screening

All clients and beneficial owners are screened against:

• OFAC Specially Designated Nationals (SDN) list
• OFAC Consolidated Sanctions List (CSL)
• U.S. Bureau of Industry and Security Entity List
• UN Security Council sanctions lists
• EU sanctions lists
• Other international sanctions regimes as applicable

Screening is conducted at client onboarding and periodically throughout the client relationship. Any matches trigger immediate investigation and potential service termination.

9. Record Keeping and Documentation

We maintain comprehensive records of all KYC/AML activities for a minimum of five (5) years, including:

• Client identification and verification documents
• Source of funds documentation
• Risk assessment determinations
• Sanctions screening results
• Transaction records and monitoring logs
• Investigation files and suspicious activity reports

All records are maintained securely and with appropriate access controls to prevent unauthorized disclosure.

10. Reporting Obligations

We comply with all mandatory reporting obligations, including:

• Filing Suspicious Activity Reports (SARs) with FinCEN when required
• Currency Transaction Reporting (CTR) for qualifying transactions
• Reporting to state and federal regulators as required
• International reporting obligations for cross-border transactions

We maintain a policy of non-disclosure of SARs and associated investigations consistent with regulatory requirements.

11. Staff Training and Compliance

All personnel involved in client onboarding, financial operations, or service delivery receive mandatory training on AML/KYC procedures and red flag identification. Annual compliance training is required for all staff. Management oversight ensures consistent application of AML/KYC policies across all service offerings.

12. Third-Party Service Providers

We conduct due diligence on all third-party service providers, including payment processors, advertising platforms, and technical providers. Service provider agreements include AML/KYC compliance requirements and permit us to audit their compliance procedures.

13. Policy Review and Updates

This AML/KYC policy is reviewed annually and updated to reflect changes in regulations, industry best practices, and our operational procedures. Material updates are communicated to clients and relevant stakeholders.