1. Compliance Commitment
VaultX is committed to maintaining a comprehensive Anti-Money Laundering (AML) and Know Your Customer (KYC) program in compliance with international standards, including the Financial Action Task Force (FATF) Guidelines, and applicable laws in all jurisdictions where we operate.
Our AML/KYC program is designed to:
- Prevent the use of VaultX services for money laundering, terrorist financing, and other financial crimes
- Identify and verify the identity of our customers
- Monitor transactions for suspicious activity
- Report suspected criminal activity to relevant authorities
- Maintain detailed records of customer identification and transactions
2. Know Your Customer (KYC) Verification
Initial Verification
All VaultX users must complete identity verification before accessing certain features:
- Full Legal Name: Must match government-issued identification
- Date of Birth: For age verification and identity confirmation
- Government ID: Valid passport, national ID card, or driver's license
- Proof of Address: Recent utility bill, bank statement, or government document
- Facial Verification: Selfie matching government ID for fraud prevention
- Source of Funds: Declaration of employment, business, or other income source
Beneficial Ownership
For corporate accounts, we require identification of beneficial owners (individuals controlling 25% or more of the entity) and verification of corporate documentation.
Ongoing Due Diligence
VaultX conducts ongoing monitoring of customer information. If circumstances change significantly, we may request updated documentation or enhanced due diligence information.
Enhanced Due Diligence (EDD)
For high-risk customers, large transactions, or other risk factors, we conduct enhanced due diligence including:
- Detailed source of funds investigation
- Additional documentation and verification
- Enhanced transaction monitoring
- Periodic re-verification of information
3. Transaction Monitoring
Automated Screening
All transactions are monitored using automated systems that screen for:
- Transactions involving sanctioned jurisdictions or individuals
- Unusual patterns or large transactions
- Rapid deposits and withdrawals (structuring)
- Transactions with high-risk jurisdictions or entities
Manual Review
Our compliance team conducts manual review of flagged transactions and may:
- Request additional information about transaction purpose
- Freeze transactions pending verification
- Deny transactions deemed suspicious
- File suspicious activity reports
Velocity Limits
To prevent rapid structuring of large amounts, VaultX implements transaction limits based on account age, verification level, and transaction history.
4. Suspicious Activity Reporting
Reporting Obligations
VaultX reports suspected money laundering, terrorist financing, and other financial crimes to appropriate authorities including:
- U.S. Financial Crimes Enforcement Network (FinCEN)
- U.S. Office of Foreign Assets Control (OFAC)
- Financial intelligence units in applicable jurisdictions
- Local law enforcement agencies
- Regulatory authorities in relevant countries
Reporting Standards
Suspicious activity reports are filed based on objective indicators of potential criminal activity, including:
- Transactions inconsistent with customer profile or source of funds
- Attempts to circumvent AML controls
- Multiple transactions structured to avoid detection
- Transactions involving sanctioned jurisdictions or persons
- Customer behavior indicating fraud or criminal intent
Confidentiality
VaultX maintains strict confidentiality regarding suspicious activity reports. We do not disclose to customers that a suspicious activity report has been filed.
5. Restricted Jurisdictions & Persons
Sanctioned Jurisdictions
VaultX does not provide services to residents of or entities controlled by the following jurisdictions:
- Iran
- North Korea
- Syria
- Crimea
- Any jurisdiction designated as a state sponsor of terrorism
- Any jurisdiction subject to comprehensive U.S. sanctions
Specially Designated Nationals (SDN)
VaultX screens all customers against the OFAC SDN list and other government sanctions lists. Customers identified as SDN-designated persons are immediately account-restricted and reported to authorities.
Politically Exposed Persons (PEP)
Customers identified as politically exposed persons or their immediate family members are subject to enhanced due diligence and ongoing monitoring.
6. Record Keeping & Retention
Required Records
VaultX maintains detailed records of:
- Customer identification and verification documents
- Account application and originating forms
- All transaction records and details
- Beneficial ownership documentation
- Correspondence and communication with customers
- Suspicious activity reports and investigations
Retention Period
Records are retained for the following periods:
- Customer Identification Records: 5 years after account closure
- Transaction Records: 7 years per anti-money laundering regulations
- Beneficial Ownership Documents: 5 years after account closure
- Suspicious Activity Reports: 7 years from filing
Record Accessibility
Records are maintained in a secure, accessible format and are produced immediately upon request by authorized law enforcement or regulatory agencies.
7. Staff Training & Compliance
Mandatory Training
All VaultX employees with access to customer information or transaction data are required to complete:
- Initial AML/KYC compliance training before accessing systems
- Annual refresher training on AML regulations and VaultX procedures
- Specific training on identifying money laundering indicators
- Training on proper handling of sanctions lists and OFAC compliance
Compliance Culture
VaultX maintains a strong compliance culture where:
- AML/KYC compliance is a core business value
- Employees are empowered to raise compliance concerns
- Anti-retaliation policies protect compliance whistleblowers
- Management oversight ensures consistent application of policies
8. Compliance Officer
Designated Officer
VaultX has designated a Chief Compliance Officer responsible for:
- Oversight of the AML/KYC program
- Policy development and updates
- Staff training and compliance monitoring
- Investigation of suspicious activity
- Regulatory reporting and liaison
- Program testing and evaluation
Contact Information
Chief Compliance Officer
Email: compliance@vaultx.io
VaultX Inc., 123 Blockchain Avenue, San Francisco, CA 94105, USA
Last Updated: April 2026