AML & Compliance Policy

Last updated: April 16, 2026

1. Overview

Sureva, Inc. is a registered Money Services Business (MSB) committed to preventing money laundering, terrorist financing, and other financial crimes. This policy outlines our compliance framework and the measures we take to ensure the integrity of our platform.

Sureva is registered with FinCEN as a Money Services Business and maintains compliance with the Bank Secrecy Act (BSA) and applicable state regulations.

2. Regulatory Framework

Our compliance program adheres to:

• Bank Secrecy Act (BSA)
• USA PATRIOT Act
• FinCEN regulations and guidance
• Office of Foreign Assets Control (OFAC) sanctions
• State money transmitter laws and regulations
• Financial Action Task Force (FATF) recommendations
• EU Anti-Money Laundering Directives (where applicable)

3. Know Your Customer (KYC)

We implement robust KYC procedures to verify the identity of all users:

Individual Verification

• Government-issued photo identification
• Proof of address (utility bill, bank statement)
• Biometric verification where applicable
• Liveness detection for fraud prevention

Business Verification (KYB)

• Business registration documents
• Certificate of incorporation
• Beneficial ownership information
• Director and officer identification
• Business address verification

Verification is conducted through our partnership with Stripe Connect, which provides industry-leading identity verification and compliance services.

4. Transaction Monitoring

We employ sophisticated transaction monitoring systems to detect suspicious activity:

• Real-time transaction screening against sanctions lists
• Pattern analysis for unusual transaction behavior
• Velocity checks and threshold monitoring
• Geographic risk assessment
• Peer group analysis and anomaly detection

5. Sanctions Screening

All users and transactions are screened against global sanctions lists including:

• OFAC Specially Designated Nationals (SDN) List
• UN Security Council Consolidated List
• EU Consolidated List
• UK HM Treasury Sanctions List
• Other relevant national and international sanctions lists

6. Suspicious Activity Reporting

We are committed to filing Suspicious Activity Reports (SARs) with FinCEN when we detect:

• Transactions that appear to lack business or lawful purpose
• Attempts to evade reporting or recordkeeping requirements
• Unusual patterns inconsistent with expected activity
• Transactions involving sanctioned persons or entities
• Any activity suggesting money laundering or terrorist financing

7. Prohibited Activities

The following activities are strictly prohibited on our platform:

• Money laundering or terrorist financing
• Transactions with sanctioned countries, entities, or individuals
• Illegal gambling operations
• Drug trafficking proceeds
• Human trafficking
• Fraud or fraudulent schemes
• Tax evasion
• Unlicensed money transmission

8. Record Keeping

We maintain comprehensive records in accordance with regulatory requirements:

• Customer identification records: 5 years after account closure
• Transaction records: 5 years from date of transaction
• SAR records: 5 years from filing date
• Compliance policies and procedures: Duration of business plus 5 years

9. Compliance Program

Our compliance program includes:

• Designated Compliance Officer responsible for program oversight
• Written policies and procedures
• Employee training and awareness programs
• Independent testing and audits
• Risk-based approach to compliance
• Board and senior management oversight

10. Reporting Concerns

If you suspect any suspicious activity or have compliance concerns, please contact us:

Compliance Department

Sureva, Inc.

Email: compliance@sureva.com

Reports may be submitted confidentially.