KYC & AML Policy

1. INTRODUCTION

1BD.club (“Platform,” “we,” “us,” or “our”), owned and operated by OxMetaLabs, Inc., is committed to preventing money laundering, terrorist financing, fraud, and other financial crimes. This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy (“Policy”) outlines the principles and procedures we have implemented to comply with applicable laws and regulations while maintaining the integrity of our Web3 platform.

This Policy is designed to establish a framework for identifying, verifying, and monitoring users and their activities on our platform. It aims to detect and prevent suspicious activities that may be connected to money laundering, terrorist financing, or other illicit activities.

2. PURPOSE AND SCOPE

2.1 Purpose

The purpose of this Policy is to:

• Establish clear guidelines for customer identification and verification
• Implement effective risk assessment and management procedures
• Define ongoing monitoring protocols for user activities
• Ensure compliance with applicable laws and regulations
• Protect the platform and its users from financial crimes
• Maintain the integrity of our services within the Web3 ecosystem

2.2 Scope

This Policy applies to:

• All employees, officers, and directors of OxMetaLabs, Inc.
• All users of 1BD.club and its associated services and applications
• All transactions and activities conducted through our platform
• All business relationships established with partners and service providers

3. REGULATORY FRAMEWORK

1BD.club is committed to complying with all applicable KYC and AML laws, regulations, and industry standards, including but not limited to:

• Financial Action Task Force (FATF) Recommendations
• Bank Secrecy Act (BSA)
• USA PATRIOT Act
• European Union Anti-Money Laundering Directives (AMLD)
• Financial Crimes Enforcement Network (FinCEN) guidelines
• Local regulations in jurisdictions where we operate

We regularly monitor changes in the regulatory landscape and update our policies and procedures accordingly.

4. RISK-BASED APPROACH

1BD.club employs a risk-based approach to KYC and AML compliance. This approach allows us to allocate resources efficiently by focusing enhanced due diligence on higher-risk users, transactions, and activities.

4.1 Risk Factors

We consider the following risk factors when assessing potential money laundering and terrorist financing risks:

4.1.1 User Risk Factors

• Geographic location and jurisdiction
• Nature of business activities
• Politically Exposed Person (PEP) status
• Adverse media or sanctions listings
• Complexity of ownership structure (for business entities)
• Source of funds
• Transaction patterns and history

4.1.2 Service Risk Factors

• Type of service provided
• Transaction volumes and frequency
• Anonymity features
• Cross-border elements
• Integration with third-party services

4.1.3 Geographic Risk Factors

• High-risk jurisdictions identified by FATF
• Countries subject to sanctions
• Countries known for high levels of corruption
• Countries associated with terrorist activities
• Offshore financial centers with weak AML controls

4.2 Risk Categories

Based on our risk assessment, users are categorized as:

• Low Risk: Basic KYC procedures apply
• Medium Risk: Standard KYC procedures apply
• High Risk: Enhanced Due Diligence (EDD) procedures apply

Risk levels are continuously reassessed based on user activity and emerging threats.

5. KYC PROCEDURES

5.1 Customer Identification Program (CIP)

1BD.club implements a robust Customer Identification Program (CIP) to verify the identity of each user before allowing full access to our platform and services.

5.1.1 Individual Users

For individual users, we collect and verify the following information:

• Full legal name
• Date of birth
• Residential address
• Nationality
• Government-issued identification document (passport, national ID card, or driver’s license)
• Email address
• Phone number
• Selfie or video verification where applicable

5.1.2 Business Entities

For business entities, we collect and verify the following information:

• Legal name of entity
• Legal form and status
• Registration number
• Principal place of business
• Mailing address (if different)
• Nature of business
• Beneficial ownership information for all individuals who own 25% or more
• Identity verification of authorized representatives
• Corporate documents (certificate of incorporation, articles of association, etc.)
• Proof of address

5.2 Verification Methods

1BD.club employs various methods to verify the identities of our users, which may include:

• Document verification: Analysis of government-issued ID documents
• Biometric verification: Facial recognition and liveness detection
• Database checks: Verification against reliable and independent databases
• Proof of address verification: Utility bills, bank statements, etc.
• Digital identity verification: Decentralized identity solutions, verifiable credentials
• Blockchain analytics: Analysis of blockchain transactions and wallet addresses

5.3 Enhanced Due Diligence (EDD)

For high-risk users, we implement Enhanced Due Diligence procedures, which may include:

• Additional verification steps
• Source of funds and wealth documentation
• More frequent review of user information
• Senior management approval
• Enhanced transaction monitoring
• Verification of business activities
• Face-to-face or video verification

5.4 Politically Exposed Persons (PEPs)

1BD.club has specific procedures for identifying and managing relationships with PEPs:

• Identification of PEPs through screening against PEP databases
• Mandatory EDD for all identified PEPs
• Senior management approval before establishing business relationships
• Ongoing enhanced monitoring of PEP activities
• Regular review and risk reassessment

5.5 Sanctions Screening

We screen all users against relevant sanctions lists, including but not limited to:

• UN Security Council Consolidated List
• OFAC Specially Designated Nationals (SDN) List
• EU Consolidated Financial Sanctions List
• UK HM Treasury Sanctions List
• Local sanctions lists in relevant jurisdictions

Screening is conducted at onboarding and regularly throughout the business relationship.

6. AML PROCEDURES

6.1 Transaction Monitoring

1BD.club implements an automated transaction monitoring system to detect suspicious activities. The system flags transactions based on predefined parameters, including:

• Unusual transaction patterns
• Transaction amounts above certain thresholds
• Transactions with high-risk jurisdictions
• Rapid movement of funds
• Structuring of transactions to avoid reporting requirements
• Transactions with sanctioned entities or individuals
• Unusual wallet activity

6.2 Red Flags

We have identified the following red flags that may indicate potential money laundering or terrorist financing activities:

• Multiple accounts under the same user
• Frequent changes to user information
• Transactions with no apparent business purpose
• Transactions inconsistent with user profile
• Reluctance to provide required information
• Use of complex transaction structures
• Transactions involving high-risk jurisdictions
• Unusual source of funds
• Adverse media mentions
• Association with known criminal activities
• Use of multiple wallet addresses for a single user

6.3 Suspicious Activity Reporting

We maintain procedures for internal reporting of suspicious activities and, where required by law, for filing Suspicious Activity Reports (SARs) with relevant authorities. Our procedures include:

• Internal escalation process for potential suspicious activities
• Comprehensive investigation of flagged activities
• Documentation of findings and decisions
• Timely filing of SARs with appropriate authorities
• Confidentiality of SAR filings
• Non-disclosure to subjects of SAR filings
• Cooperation with law enforcement inquiries

6.4 Recordkeeping

1BD.club maintains comprehensive records of all customer identification documents, verification results, transaction history, and any investigations conducted. Records are kept for a minimum of five years after the end of the business relationship or the completion of a transaction, in accordance with applicable regulations.

7. COMPLIANCE STRUCTURE

7.1 Compliance Officer

1BD.club has appointed a dedicated Compliance Officer responsible for:

• Developing and implementing KYC/AML policies and procedures
• Ensuring compliance with applicable laws and regulations
• Providing guidance and training to staff
• Reviewing and investigating suspicious activities
• Submitting required regulatory reports
• Conducting periodic risk assessments
• Remaining informed about regulatory changes
• Reporting to senior management on compliance matters

7.2 Training

All employees receive regular training on KYC/AML procedures, including:

• Identification and verification requirements
• Risk assessment methodologies
• Red flags for suspicious activities
• Internal reporting procedures
• Recordkeeping requirements
• Relevant regulatory updates
• Role-specific responsibilities

Training is provided at onboarding and at least annually thereafter.

7.3 Independent Audit

1BD.club conducts regular independent audits of our KYC/AML program to assess its effectiveness and identify areas for improvement. Audit findings are reported to senior management and addressed promptly.

8. WEB3-SPECIFIC CONSIDERATIONS

As a Web3 platform, 1BD.club implements additional measures specifically designed for blockchain-based services:

8.1 Wallet Address Monitoring

We utilize blockchain analytics tools to monitor wallet addresses associated with our users for:

• Links to darknet markets
• Connections to sanctioned addresses
• High-risk transaction patterns
• Known scam or fraud addresses
• Mixing services or tumblers
• Privacy coin conversions

8.2 Decentralized Identity Solutions

1BD.club leverages decentralized identity solutions where appropriate to enhance privacy while maintaining compliance. These may include:

• Decentralized Identifiers (DIDs)
• Verifiable Credentials
• Zero-Knowledge Proofs (ZKPs)
• Self-Sovereign Identity (SSI) frameworks

8.3 Travel Rule Compliance

We comply with FATF’s Travel Rule requirements for virtual asset transfers by:

• Collecting and verifying required originator and beneficiary information
• Securely transmitting this information to other Virtual Asset Service Providers (VASPs)
• Implementing technical standards for travel rule compliance (e.g., IVMS101)
• Participating in industry travel rule solutions

8.4 DeFi Integration

For any decentralized finance (DeFi) integrations, we implement appropriate controls to maintain compliance while preserving the benefits of decentralization.

9. DATA PROTECTION AND PRIVACY

1BD.club is committed to protecting user data in compliance with applicable data protection laws, including GDPR and CCPA. Our approach to data handling in the context of KYC/AML includes:

• Collecting only necessary information for compliance purposes
• Storing data securely with appropriate technical and organizational measures
• Processing data in accordance with our Privacy Policy
• Providing users with information about how their data is used
• Enabling users to exercise their data rights where applicable
• Implementing data minimization and purpose limitation principles
• Establishing appropriate data retention periods

10. USER RIGHTS AND OBLIGATIONS

10.1 User Rights

Users have the right to:

• Be informed about our KYC/AML requirements
• Access personal information we hold about them
• Request correction of inaccurate information
• Submit complaints about our procedures
• Withdraw from our services (subject to recordkeeping requirements)

10.2 User Obligations

Users are obligated to:

• Provide accurate and complete information
• Update information when changes occur
• Comply with verification requests
• Respond to inquiries related to KYC/AML requirements
• Refrain from using our services for illegal activities

11. POLICY REVIEW AND UPDATES

This Policy is reviewed at least annually and updated as needed to reflect:

• Changes in applicable laws and regulations
• Emerging risks and threats
• Evolving industry best practices
• Internal audit findings
• Feedback from regulators
• Technological advancements

Users will be notified of significant changes to this Policy.

12. CONTACT INFORMATION

For questions about this Policy or our KYC/AML procedures, please contact:

Compliance Department
OxMetaLabs, Inc.
Email: compliance@0xmetalabs.com
Website: www.0xmetalabs.com

13. DISCLAIMER

1BD.club is committed to preventing the use of our platform for money laundering, terrorist financing, or other illicit activities. However, our KYC/AML measures should not be construed as providing legal, financial, or professional advice. Users are encouraged to consult with appropriate professionals regarding their specific circumstances and obligations.

This Policy is designed to comply with applicable regulations while balancing user privacy and the ethos of Web3. We strive to maintain this balance by implementing proportionate risk-based controls that protect our platform and users without unnecessarily restricting legitimate activities.

By using 1BD.club services, you acknowledge that you have read, understood, and agree to comply with this KYC & AML Policy.