AML/KYC Policy

The AML/KYC Policy ensures compliance with anti-money laundering and “Know Your Customer” regulations. It requires users to verify their identities, preventing illegal activities like money laundering or fraud. The policy promotes transparency, safeguarding both the platform and its users

Real Tokniz Platforms LLC, SVG (“we,” “our,” or “us”) is committed to complying with all applicable Anti-Money Laundering (AML) and Know Your Customer (KYC) laws and regulations. Our AML/KYC policy is designed to prevent and mitigate the risks of money laundering, terrorist financing, and other illicit financial activities across our platform, including the following websites:

By using our services, you agree to adhere to the AML/KYC procedures outlined in this policy.

Objectives

The primary objectives of this AML/KYC policy are:

  • To prevent the platform from being used for illegal purposes such as money laundering and terrorist financing.
  • To verify the identity of users and clients.
  • To ensure that we are compliant with global and local AML regulations, including but not limited to regulations in Saint Vincent and the Grenadines and other applicable jurisdictions.
  • To take appropriate measures when suspicious activity is detected.

User Identification and KYC Verification

We have implemented a rigorous KYC procedure to verify the identity of all users who seek to engage in tokenized real estate transactions or use any financial services offered through our platforms.

KYC Information Requirements

Users will be required to provide the following information:

For Individuals

  • Full legal name
  • Date of birth
  • Nationality
  • Residential address
  • Valid government-issued ID (e.g., passport, driver’s license, or national ID)
  • Proof of address (utility bill, bank statement, etc., not older than three months)
  • Selfie or live video for biometric verification (where applicable)

For Businesses and Legal Entities

  • Legal entity name
  • Business registration number
  • Registered business address
  • Incorporation documents (Certificate of Incorporation, Articles of Association)
  • Proof of entity’s directors and beneficial owners (names, ownership structure)
  • Valid identification for directors and beneficial owners
  • Proof of address for directors and beneficial owners

Verification Process

  • All KYC documentation will be reviewed and verified by our compliance team. We reserve the right to use third-party services for identity verification, including biometric verification and database checks.
  • The verification process may take several days, and users will not be able to complete certain transactions until the verification is successfully completed.
  • In certain cases, we may request additional documentation or information to comply with regulatory requirements.

Risk-Based Approach

We employ a risk-based approach to AML/KYC compliance, meaning that the level of due diligence required for each user is proportional to the perceived level of risk.

Customer Risk Assessment

  • Low-risk customers: Users whose activities and profile present minimal risk of money laundering or other illegal activities. Basic KYC requirements apply.
  • Medium-risk customers: Users with a higher level of transactional activity or those from jurisdictions with known AML/CFT risks. Enhanced due diligence (EDD) may apply.
  • High-risk customers: Users from jurisdictions with significant money laundering risks, or users engaging in high-volume or complex transactions. EDD and ongoing monitoring will apply.

Transaction Monitoring

We monitor all transactions on our platforms to detect any suspicious activity. This includes, but is not limited to:
  • Large transactions or sudden spikes in activity.
  • Unusual patterns of behavior, such as frequent withdrawals, rapid token transfers, or attempts to obfuscate transaction origins.
  • Transactions involving high-risk jurisdictions or entities known for criminal activity.
If we detect suspicious activity, we will conduct further investigation and, if necessary, report the activity to the relevant regulatory authorities.

Enhanced Due Diligence (EDD)

For higher-risk users and transactions, we apply Enhanced Due Diligence (EDD) procedures, which may include:
  • Verifying the source of funds and wealth of the user.
  • Requesting additional documentation, such as contracts, financial statements, or tax records.
  • Closely monitoring the user’s activity over an extended period.
  • Conducting ongoing reviews of the user’s profile and transactions.

EDD may also be triggered in response to any red flags identified through transaction monitoring or external data sources.

Sanctions and Politically Exposed Persons (PEP) Screening

We screen all users and transactions against global sanctions lists and databases of Politically Exposed Persons (PEPs), including:
  • United Nations Sanctions List
  • European Union Sanctions List
  • U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC)
  • Other relevant international and national watchlists

Users who are identified as PEPs or are associated with sanctioned entities may be subject to additional scrutiny or restrictions on their use of the platform.

Record Keeping

In compliance with AML/KYC regulations, we maintain records of all user information, transaction data, and verification processes for a minimum of five (5) years after the termination of the business relationship. This data will be securely stored and accessible only to authorized personnel.
We are required to provide these records to regulatory authorities upon request, subject to legal or regulatory requirements.

Reporting Obligations

We are committed to fulfilling our reporting obligations under applicable AML laws. This includes the following types of reporting:
  • Suspicious Activity Reporting (SAR): We will file a SAR if we suspect that a user or transaction is involved in money laundering, terrorist financing, or other illegal activities.
  • Threshold Reporting: Certain transactions exceeding specific thresholds may trigger mandatory reporting to the relevant financial authorities.
We will not inform users if a report is filed in relation to their activity, as this may be prohibited under AML regulations.

Training and Awareness

We provide ongoing AML/KYC training to our employees, including staff responsible for user onboarding, transaction monitoring, and compliance. Training includes:
  • Identifying suspicious activity.
  • Understanding regulatory requirements.
  • Implementing AML/KYC procedures and protocols.
  • Responding to compliance-related inquiries.

Penalties for Non-Compliance

Non-compliance with our AML/KYC policies may result in:
  • Suspension or termination of the user’s account.
  • Freezing of funds or assets held on the platform.
  • Reporting to relevant authorities, which could lead to legal action.

Changes to This Policy

We reserve the right to modify or update this AML/KYC policy at any time. Any changes will be posted on our websites, and the “Effective Date” will be updated accordingly. Your continued use of the platform after any changes indicates your acceptance of the revised policy.