> For the complete documentation index, see [llms.txt](https://pleasing.gitbook.io/docs/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://pleasing.gitbook.io/docs/legal/aml-cft-and-sanctions-policy.md). # AML/CFT & Sanctions Policy **Purpose**\ Pleasing International Limited (“**Pleasing Market**”, “**we**”, “**us**”) is committed to combating **money laundering (ML)**, **terrorist financing (TF)**, proliferation financing, and related financial crime. We comply with applicable **Anti-Money Laundering (AML)**, **Counter-Terrorist Financing (CTF)**, and **sanctions** laws and regulations in the jurisdictions where we operate. Collectively, these controls form our **AML Program**. *** ### 1. AML Program Overview Our AML Program is designed to ensure compliance with applicable legislation and to maintain effective risk-based controls. Core components include: * **Written Policies & Internal Controls**\ Documented procedures to identify, assess, mitigate, and monitor AML/CTF/sanctions risk across onboarding, tokenization, trading, redemption, and treasury operations. * **Governance & Accountability** * **Board/Senior Management** oversight of the AML Program. * Appointment of a **Money Laundering Reporting Officer (MLRO)** responsible for day-to-day effectiveness and regulatory reporting. * Designated **Compliance Officers** for ongoing monitoring, quality assurance, and issue management. * **Risk-Based Approach (RBA)**\ Enterprise, product, customer, jurisdiction, distribution channel, and delivery risk assessments—updated periodically or upon trigger events. * **KYC/KYB Standards**\ Identification and verification of all customers and **Relevant Persons** (UBOs/controlling persons, directors, authorized signatories). Collection of **purpose of account**, **source of funds**, and **source of wealth** during onboarding. * **Screening & Monitoring**\ Sanctions, PEP, adverse media screening at onboarding and ongoing; real-time and post-event **transaction monitoring** (TM) and **Know-Your-Transaction (KYT)** for fiat and on-chain activity, with blockchain analytics where appropriate. * **Enhanced Due Diligence (EDD)**\ Applied to higher-risk customers or scenarios (e.g., PEP nexus, high-risk geographies/industries, adverse media, anomalous on-chain behavior, complex structures). * **Suspicious Activity Escalation & Reporting**\ Documented investigation workflow and reporting to relevant competent authorities where required. * **Training**\ **Annual, mandatory AML/CFT training** for all employees; onboarding training for new hires; role-specific refreshers for high-risk functions. * **Independent Testing**\ Periodic independent audit/review to assess design and operating effectiveness. * **Recordkeeping**\ Retention of KYC/KYB, screening, TM/KYT, and reporting records for legally prescribed periods. *** ### 2. Prohibited Business Relationships Pleasing Market **will not** establish or maintain relationships with: * Individuals or entities subject to **international or local sanctions** (e.g., UN, OFAC, UK HMT, EU, HK/other applicable authorities). * Persons known or reasonably suspected to engage in **terrorist financing**, organized crime, or to act on behalf of such organizations. * **Shell banks** (no physical presence) or counterparties refusing to disclose ownership/control information. * Clients operating under **fictitious names/pseudonyms**. * Businesses primarily involved in: **weapons/armaments trade**, **tobacco trading**, **adult entertainment**, or **casinos/gambling** where prohibited by applicable policy or law. > We reserve the right to decline or exit relationships that present unacceptable AML/CTF/sanctions risk. *** ### 3. Prohibited Assets & Funds We will not knowingly accept, transfer, or facilitate funds or digital assets that we determine (via KYC/KYB/KYT, TM, or other means) to be **criminal proceeds**, used for **terrorist financing**, or linked to a **criminal organization**, even if the underlying conduct occurred outside our primary jurisdiction. *** ### 4. Restricted Jurisdictions We will not enter into or will exit business relationships where a customer, beneficial owner, controlling person, or relevant activity is connected to **restricted/prohibited jurisdictions**, including jurisdictions subject to comprehensive sanctions or identified as presenting **unacceptable AML/CTF risk** under our risk assessment and policy. *** ### 5. KYT / Transaction Monitoring at Pleasing Market We prohibit the use of our platforms for **illegal activities** (e.g., ML, TF, sanctions evasion, fraud). * We conduct **real-time and continuous KYT/TM** on transactions (fiat and on-chain). * When we detect suspected illicit activity, we may: **reject funds**, **freeze accounts/tokens** where legally permissible, **request information (RFI)**, restrict services, and/or **file suspicious activity reports** with relevant authorities. * We reserve all contractual and legal rights to protect the integrity of our platform and comply with law. *** ### 6. Prohibited / High-Risk Transaction Activity (Illustrative) * Transactions that violate—or cause us to violate—**sanctions laws** administered by relevant authorities (e.g., OFAC, UN, EU, UK, HK/others as applicable). * Transactions linked to **fraud, scams, stolen funds, ransomware, malware**, or other predicate offenses. * Use of **mixers/tumblers**, privacy-enhancing techniques designed to obfuscate provenance, or **dark-net markets**. * **Gambling** activity where prohibited by law or our policy. * **Structuring**, rapid in-and-out movement of funds (e.g., immediate withdrawals post-deposit) without legitimate business rationale. * Attempts to circumvent **KYC/KYB**, **source-of-funds/wealth** disclosures, or **screening**. *** ### 7. Precious-Metals / RWA-Specific Controls Given our focus on tokenized precious metals (e.g., **PGOLD**): * **Inventory & Redemption Controls:** KYC-enabled redemption; matching physical flows with token movements; audit trails for mint/burn events. * **Supply-Chain Due Diligence:** Verification of vault providers, logistics, and insurance; assessment of **origin** and **chain-of-custody** where applicable. * **On-Chain Transparency:** Use of analytics, **Proof-of-Reserve (PoR)** attestations, and risk alerts to support market integrity. *** ### 8. Responsibilities of Customers and Partners Customers, issuers using our Tokenization-as-a-Service, and ecosystem partners must: * Provide accurate and complete **KYC/KYB** information and promptly update changes. * Disclose **beneficial ownership/controlling persons** and cooperate with EDD requests. * Refrain from engaging in **Prohibited Uses** or activity that could expose Pleasing Market to AML/CTF/sanctions risk. * Acknowledge that services may be **delayed, suspended, or terminated** to comply with law or our AML Program. *** ### 9. Reporting & Contact To report suspicious activity or raise AML/CTF concerns, contact: **** (subject: **“AML REPORT”**).\ Please do **not** include sensitive information beyond what is necessary for us to review your concern; we will follow up securely if additional detail is required. *** ### 10. Policy Review This Policy may be updated periodically to reflect regulatory changes, audit findings, or program enhancements. The latest version will be posted on our website/app.