KYC/AML Policy

Feeturre LLC (“Feeturre,” “Company,” “we,” “us,” or “our”) is committed to maintaining a secure platform and implementing risk-based compliance measures designed to discourage misuse of digital assets or financial systems.

This KYC / AML Policy describes the identity verification and monitoring procedures used in connection with the Feeturre Platform.

Feeturre operates as a technology platform and does not represent itself as a bank or regulated financial institution except as required under applicable law.

1. Scope

This policy applies to Users who:

• Purchase Tokens using fiat currency
• Conduct Wallet transactions
• Request payouts
• Engage in high-value or high-frequency activity
• Participate in Escrow transactions
• Host monetized listings, events, or contests

Feeturre reserves the right to apply verification measures based on risk assessment.

2. Identity Verification (KYC)

2.1 Verification Provider

All identity verification is conducted through Veriff, an independent third-party identity verification provider.

When identity verification is required, Users are redirected to Veriff’s secure verification environment.

Veriff processes identity data in accordance with its own privacy policy and regulatory obligations.

2.2 Information Collected for Verification

Verification may require submission of:

• Government-issued identification
• Selfie or biometric comparison for liveness verification
• Full legal name
• Date of birth
• Address information

Biometric comparison and identity validation are performed by Veriff.

Feeturre does not independently process or store biometric templates used for identity comparison unless required for compliance or regulatory reasons.

Feeturre may receive:

• Verification status (approved / declined / requires review)
• Risk indicators
• Limited confirmation data necessary for compliance and fraud prevention

2.3 When Verification May Be Required

Verification may be required:

• Prior to fiat transactions
• Prior to withdrawals
• When transaction thresholds are met
• When suspicious activity is detected
• When required by payment processors
• When required by applicable law

Feeturre may restrict functionality until verification is completed.

2.4 Refusal or Failure to Verify

If a User:

• Refuses to complete verification
• Fails verification
• Submits false information

Feeturre may:

• Restrict Wallet functionality
• Delay or cancel transactions
• Freeze account balances pending review
• Suspend or terminate the Account

Feeturre is not required to disclose internal fraud detection criteria.

3. Risk-Based Monitoring

In addition to Veriff identity verification, Feeturre may implement risk-based monitoring mechanisms, including:

• Transaction velocity monitoring
• Pattern analysis
• Escrow misuse detection
• Behavioral anomaly detection
• Fiat-to-Token conversion monitoring

Monitoring may rely on internal systems and third-party risk tools.

4. Sanctions Screening

Users may be screened against sanctions lists, including:

• U.S. OFAC lists
• Other applicable international sanctions lists

Users located in sanctioned jurisdictions or appearing on restricted lists may be denied access.

5. Suspicious Activity

Where suspicious activity is identified, Feeturre may:

• Restrict or freeze accounts
• Delay or reverse internal ledger transactions
• Request additional documentation
• Cooperate with lawful regulatory or law enforcement inquiries

6. Recordkeeping

Feeturre may retain:

• Verification status results
• Transaction histories
• Compliance review records

Retention periods are determined based on legal obligations, fraud prevention requirements, accounting standards, and dispute resolution needs.

Certain information may be retained even after account deletion where legally required.

7. Cooperation With Authorities

Feeturre may cooperate with lawful investigations and regulatory inquiries in accordance with applicable law.

8. Policy Updates

Feeturre may update this KYC / AML Policy to reflect regulatory developments, operational changes, or risk adjustments.

Continued use of the Platform constitutes acceptance of the updated policy.