Legal

AML / KYC Policy

Last updated: April 23, 2026

AWASHDIRECT LLC, operating as Servicio UniTeller, Inc., maintains an Anti-Money Laundering ("AML") and Know Your Customer ("KYC") program designed to comply with applicable U.S. financial regulations, including the Bank Secrecy Act (BSA) and FinCEN regulations applicable to Money Services Businesses.

1. Program governance

We have appointed a designated Compliance Officer responsible for the implementation, ongoing monitoring, and periodic review of our AML and KYC program. The program is reviewed and updated to reflect changes in applicable laws, regulatory guidance, and our risk profile.

2. Customer Identification Program (CIP)

Before activating wallet features, we collect and verify identifying information from each customer, which may include:

Identity verification is performed using a combination of documentary and non-documentary methods. We may request additional information at any time to confirm identity or address risk-based factors.

3. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

We perform risk-based due diligence on customers and their expected activity. Higher-risk customers, products, or transactions may be subject to Enhanced Due Diligence, including additional documentation, source-of-funds inquiries, and senior compliance review.

4. Sanctions screening

We screen customers and counterparties against applicable sanctions lists, including those administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC). Matches result in account restrictions and, where applicable, mandatory reporting.

5. Transaction monitoring

We use risk-based controls to monitor account activity for unusual or potentially suspicious patterns, including (without limitation) structuring, rapid pass-through activity, transactions involving sanctioned jurisdictions, and patterns inconsistent with the customer's stated profile.

6. Suspicious Activity Reporting (SAR) and other reporting

Where required by law, we file Suspicious Activity Reports and Currency Transaction Reports with FinCEN. The existence and contents of such reports are confidential as required by law.

7. Recordkeeping

We retain customer identification, transaction, and compliance records for the periods required by applicable law and regulation, and in line with our internal records retention schedule.

8. Training

Personnel with AML responsibilities receive training appropriate to their roles, covering applicable laws and regulations, internal policies and procedures, and red flags relevant to digital asset services.

9. Independent review

The AML program is subject to periodic independent review consistent with applicable regulatory expectations.

10. Customer obligations

Customers are required to provide accurate and current information, respond to verification requests in a timely manner, and refrain from using the Services for any unlawful purpose. Failure to do so may result in account restrictions or termination.

11. Geographic restrictions

Certain Services may not be available in all U.S. states or jurisdictions. We may decline to onboard or to provide Services to customers in jurisdictions where doing so would conflict with applicable law or our internal risk policies.

12. Independent verification of registration

Customers and counterparties may verify our registration and licensing through:

13. Contact

Compliance inquiries: admin@serviciounitellerinc.com — AWASHDIRECT LLC, 218 Route 17 North, 4th Floor, Rochelle Park, NJ 07662, United States.