1. Objective and Scope
This Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) Policy sets out the measures applied by SharedState ("the Platform") to prevent, detect, and report money laundering, terrorist financing, sanctions evasion, bribery, corruption, tax evasion, and other financial crimes. This policy applies to all users, transactions, projects, administrators, and service providers connected to the Platform.
2. Risk-Based Approach
The Platform applies a risk-based approach. Controls are proportionate to the assessed risk of a user, transaction, or project. Higher-risk scenarios — such as large aggregate transactions, politically exposed persons (PEPs), users from high-risk jurisdictions, or corporate investors — trigger enhanced due diligence (EDD).
3. Know Your Customer (KYC)
a. Customer Identification Program (CIP)
- At a minimum, every user provides full name, valid email, and optional phone number during registration.
- Before taking certain actions (selling on the secondary market, participating in large distributions, or withdrawing proceeds off-platform), the user will be required to complete identity verification by uploading one or more government-issued documents and, where applicable, proof of address.
b. Identity Verification
- Documents are reviewed by authorized administrators against forgery indicators, visual liveness, name consistency with account profile, and expiry.
- Review outcomes are stored: status, reviewer, review notes, and timestamps. Users can see the status of their submission from the Settings → Identity Verification page.
c. Enhanced Due Diligence (EDD)
EDD is required for any match or reasonable suspicion of any of the following: PEPs, sanctions lists, adverse media, unusual transaction patterns, high-risk countries, corporate entities, or transactions above predefined thresholds. EDD may include source-of-wealth or source-of-funds evidence, beneficial ownership verification, and senior management sign-off before allowing the transaction.
4. Transaction Monitoring
- All share purchases, payment allocations, secondary market listings, buy requests, and dividend distributions are retained and subject to manual and automated monitoring.
- Patterns of concern include: structuring payments to avoid thresholds, rapid buy-sell sequences without economic purpose, trading with the same counterparty repeatedly, and third-party payments originating from a non-account holder.
- Every material administrator action and every listing approval or rejection is recorded in the audit log for compliance traceability.
5. Sanctions Screening
The Platform screens account names, entities, and beneficial owners against applicable sanctions lists and rejects or freezes accounts, transactions, or projects where a match is confirmed or a genuine suspicion arises. Screening occurs at onboarding, at verification, and periodically, plus at the time of any material transaction.
6. Reporting of Suspicious Activity
- Administrators and staff are required to report any suspicious transaction or activity internally without delay, and without tipping off the subject user.
- Suspicious Activity Reports (SARs), or equivalent national filings, are made to the appropriate national Financial Intelligence Unit (FIU) within the timeframes required by law.
- All supporting records and the corresponding audit-trail are preserved for the legally required retention period.
7. Record Keeping
Identity records, KYC documents, transaction evidence, approvals, transfer ledgers, and compliance notes are retained for at least five years after account closure or the completion of the transaction, consistent with international AML/CTF standards and national obligations, whichever is longer.
8. Staff Training and Governance
- All administrators and relevant staff complete AML/CTF awareness training on onboarding and at least annually thereafter.
- Overall responsibility for this policy rests with the senior management of the Platform. Compliance effectiveness is reviewed annually.
9. Third-Party and Project Onboarding Due Diligence
Issuers, sponsors, project promoters, property managers, and payment partners onboarded by the Platform are themselves subject to due diligence proportional to their role and risk profile — including, where applicable, beneficial ownership, corporate documents, licensing, sanctions screening, and adverse-media checks.
10. User Cooperation
Users must, upon reasonable request, cooperate with any compliance review by promptly providing accurate information and documents. Failure to do so may result in restricted account functionality, withheld distributions, or suspension of account privileges pending completion of review.
11. Policy Maintenance
This AML/KYC Policy is reviewed annually or earlier if required by material changes in the business model, applicable law, or regulator guidance. Updates are reflected on this page with the revised "Last updated" date above.