AML & KYC Policy

1. General

To ensure compliance with applicable laws and regulations, Chainberry LLC (operating under the trade name Chainberry) has established a Compliance Department responsible for Anti-Money Laundering (AML) and Know Your Customer (KYC) procedures.

• These procedures are obligatory for all employees and govern engagement with any company that uses Chainberry's services.
• The policy is designed to comply with the laws and regulations of Saint Vincent and the Grenadines.
• A designated Compliance Officer oversees implementation and enforcement.
• The policy is reviewed annually, and all AML/KYC records are retained for at least 7 years in line with regulatory requirements.

This AML & KYC Policy should be read together with Chainberry's Compliance Strategy, which outlines the company's regulatory approach, risk management principles, and business model boundaries. In case of conflict, the Compliance Strategy prevails.

Client Scope
Chainberry provides services exclusively to corporate/entity clients (B2B). We do not onboard individual/retail clients.

Custody Statement
Chainberry is an account holder at Fireblocks and provides custody of client assets via Fireblocks' institutional platform. Client assets are held in segregated wallets with strong operational controls and security procedures.

2. Know Your Customer (KYC)

Chainberry follows a rigorous KYC verification process to collect and verify required information about clients and persons within their corporate structure.

• Anonymous accounts are not permitted.
• Additional documents may be requested at any time.
• Failure to provide required documents may result in suspension or termination of the client relationship.

3. Monitoring Transactions

Where fiat settlement occurs via approved partners, Chainberry verifies:

• the reputation of the financial institution,
• proper licensing, and
• relevant geographic compliance.

Clients may be required to designate settlement accounts, and transfers may be restricted to/from those accounts to mitigate risk.

Chainberry conducts real-time monitoring of transactions. If suspicious activity is detected (e.g., untrusted funding sources, potential fraud, or unusual activity), Chainberry reserves the right to:

• conduct an internal investigation,
• block or close the client's account,
• cancel payments, and/or
• suspend services.

4. AML / Sanctions Screening

Chainberry screens all clients, controllers, and beneficial owners to ensure protection against money laundering and terrorist financing.

• Screening includes sanctions checks and beneficial ownership verification.
• Chainberry is obligated to maintain adequate, accurate, and up-to-date client information.
• Regular re-checks are performed to confirm ongoing compliance.

5. Geographic Restrictions & Risk-Based Approach

Chainberry does not provide services to:

• Residents or entities in the United States of America.
• Jurisdictions subject to comprehensive international sanctions (e.g., DPRK, Iran).
• Any region designated as high-risk under Chainberry's risk-based framework.

Risk-based assessment also considers:

• product type,
• delivery channel,
• client background/experience, and
• adverse media.

Additional jurisdictions may be restricted over time due to regulatory changes or emerging risks.

6. Contact

For compliance-related inquiries:
📧 [email protected]