Anti-Money Laundering (AML) Policy

1. Introduction & Commitment

InfinityBlockchain LLC, a Wyoming Limited Liability Company with its registered address at 30 N Gould St, STE R, Sheridan, Wyoming (WY) 82801, USA, is committed to the highest standards of AML compliance and combating the financing of terrorism (CFT). This policy complies with US federal AML laws including the Bank Secrecy Act (BSA), USA PATRIOT Act, and FinCEN guidelines. For users in the European Union, this policy also considers obligations under the EU Anti-Money Laundering Directives (including the 6th Anti-Money Laundering Directive — 6AMLD).

2. Scope

This policy covers:

• All transactions through the Platform including purchases, commission payouts, and IB Token sales
• Card payments via Stripe and cryptocurrency payments via CoinPayments
• Commission payouts via bank transfer or cryptocurrency wallet
• IB Token purchases and MetaMask wallet deliveries
• IB Metaverse Mall rental transactions
• User registration, KYC verification, and ongoing account monitoring

3. Know Your Customer (KYC)

KYC verification may be required for:

• Payout requests above certain value thresholds
• IB Token purchases (prior to token delivery)
• Detection of suspicious or unusual account activity
• High-risk transaction patterns or account profiles

4. Customer Due Diligence (CDD)

5. Transaction Monitoring

We monitor for:

• Unusual referral patterns (circular structures, self-referrals)
• Rapid creation of multiple accounts
• Suspicious payout requests (unusual amounts, frequency, or destinations)
• Sudden large commission earnings without organic growth
• Multiple payment methods or wallets without clear business purpose
• IB Token purchases from restricted jurisdictions or via VPN circumvention
• Mall rental payments inconsistent with user profile or activity

The Company reserves the right to freeze accounts and withhold payouts pending investigation.

6. Suspicious Activity Reporting

• Suspicious Activity Reports (SARs) are filed with FinCEN as required by law.
• Currency Transaction Reports (CTRs) are filed for transactions exceeding $10,000 as required by BSA regulations.
• Per the tipping-off prohibition, users will not be informed if a SAR has been filed.
• All personnel with transaction data access receive regular AML/CFT training, including identification of suspicious activity, SAR filing procedures, and sanctions awareness. Training is documented and conducted at least annually.

7. Prohibited Activities

• Using the Platform to launder money or finance terrorism
• Creating fake referral networks to generate artificial commissions
• Using stolen, forged, or unauthorized payment methods
• Structuring transactions to avoid reporting thresholds
• Accessing the Platform from OFAC-sanctioned countries or territories
• Purchasing IB Tokens from restricted jurisdictions or circumventing geo-blocking via VPN
• Concealing the source, ownership, or destination of funds
• Providing false or misleading identity information
• Operating on behalf of undisclosed third parties

8. Sanctions Compliance

• The Company complies with OFAC sanctions programs.
• Users from sanctioned countries are prohibited from using the Platform.
• Screening against OFAC SDN List and Consolidated Sanctions List is conducted as part of due diligence.
• All users are screened against the OFAC Specially Designated Nationals (SDN) list, EU consolidated sanctions lists, and United Nations (UN) sanctions lists prior to onboarding and on an ongoing basis.
• Any transactions involving sanctioned persons, entities, or countries are strictly prohibited and will be blocked or reversed.
• Sanctions lists are updated regularly, and re-screening is performed when lists are updated or when users initiate significant transactions.

9. Record Keeping

• Transaction records maintained for a minimum of 7 years per BSA requirements.
• KYC documents retained for 5 years after end of customer relationship.
• IB Token purchase records, MetaMask wallet addresses, and investor eligibility confirmations retained for 7 years.
• All records available to authorities upon lawful request.

10. Cryptocurrency & IB Token Specific Measures

• USDC is the primary cryptocurrency for platform transactions, minimizing volatility risks.
• IB Tokens are delivered exclusively to MetaMask wallet addresses registered and verified in the user’s account profile.
• Wallet addresses are recorded and linked to user accounts for all token delivery and payout transactions.
• Blockchain analysis tools may be used to assess wallet risk scores and transaction histories.
• IB Token purchases require prior completion of KYC verification and investor eligibility confirmation.
• Token deliveries to wallets associated with sanctioned addresses or high-risk profiles will be blocked.

11. Cooperation with Authorities

• We respond to lawful subpoenas, court orders, and regulatory requests.
• We report suspicious activity to FinCEN as required by the BSA.
• We preserve records when notified of an investigation or legal proceeding.

12. Annual AML Compliance Review & Training

InfinityBlockchain LLC maintains a rigorous annual review and training program to ensure ongoing effectiveness of its AML compliance framework.

13. Policy Enforcement

Violations may result in: account suspension, permanent termination, forfeiture of commissions and balances, SAR filing with FinCEN, and pursuit of legal remedies.

14. Changes to This Policy

This policy is reviewed periodically and subject to independent audit. Updated versions will be published with a revised effective date. The AML Compliance Officer oversees annual policy reviews and ensures alignment with current BSA/FinCEN requirements and applicable international AML standards.

15. Contact

For questions about this AML Policy or to report suspicious activity: