AML Policy

Version 1.0 · Effective: October 15, 2025

Anti-Money Laundering (AML) — Public Compliance Statement

Seacrets maintains a comprehensive Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) prevention program aligned with international standards, including the recommendations of the Financial Action Task Force (FATF), applicable regulations in the United States and other relevant jurisdictions, and contractual requirements from financial institutions and payment networks.

The platform adopts a structured, proportionate, and risk-based approach to protect the integrity of the ecosystem and prevent its misuse for illicit activities.

Risk-Based Approach

Seacrets' AML/CFT program is built on a continuous risk-assessment model that considers, among other factors:

• User profile and jurisdiction.
• Nature and volume of transactions.
• Atypical operational patterns.
• Behavioral indicators inconsistent with the expected use of the service.

This approach allows proportionate and enhanced controls to be applied when the risk level warrants it.

Transaction Monitoring and Continuous Review

Seacrets implements automated mechanisms and human oversight to:

• Detect unusual or inconsistent activity.
• Identify possible structuring patterns or concealment schemes.
• Assess sudden volume increases or significant changes in financial behavior.

When elevated risk indicators are identified, the platform may apply additional diligence measures, including enhanced reviews, requests for supplementary information, or temporary account restrictions.

Operational Controls and Dynamic Limits

As part of its financial risk management program, Seacrets applies dynamic operational controls that may include, without limitation:

• Daily, cumulative, or period-based limits.
• Differentiated restrictions based on the user's risk profile.
• Preventive holds or manual reviews prior to the release of funds.
• Activation of Enhanced Due Diligence (EDD) procedures.

These controls are determined in accordance with internal risk assessments, regulatory obligations, and requirements from regulated financial institutions, and may be modified or adjusted without prior notice when circumstances require it.

The existence of these mechanisms is part of the preventive framework designed to preserve the platform's operational stability and regulatory compliance.

Reporting and Cooperation with Authorities

When required by law or when reasonable indications of illicit activity are identified, Seacrets may:

• Submit reports to competent authorities.
• Cooperate with formal investigation requests.
• Preserve records and evidence in accordance with legal obligations.

Seacrets retains documentation and operational records for the periods required by applicable regulations.

Termination Authority

The platform reserves the right to:

• Refuse to establish business relationships.
• Suspend or cancel accounts.
• Limit financial operations.

These measures may be adopted when the identified risk level is incompatible with the internal compliance framework or with applicable regulatory and contractual obligations.