Anti-Money Laundering Policy

DIRE MONEY TRANSMITTER LLC operates as a Money Services Business registered with the Financial Crimes Enforcement Network (FinCEN) under 31 CFR Part 1022. As a registered MSB engaged in money transmission and virtual currency exchange, the company is subject to the requirements of the Bank Secrecy Act (BSA), 31 U.S.C. 5311 et seq., and its implementing regulations.

The BSA requires covered financial institutions, including MSBs, to establish and maintain written anti-money laundering programs, file reports with FinCEN, and maintain records of certain transactions. This AML program fulfills those requirements.

The program is reviewed and updated periodically to reflect changes in applicable law, regulatory guidance, and the risk profile of the business.

The AML program is administered by a designated compliance officer with day-to-day responsibility for program implementation and oversight. The compliance officer is responsible for ensuring that the program remains current with applicable regulatory requirements, that employees receive appropriate training, and that suspicious activity is identified and reported in accordance with BSA obligations.

The compliance officer has the authority and resources necessary to fulfill these responsibilities. The position reports directly to senior management of DIRE MONEY TRANSMITTER LLC.

All customers must complete identity verification before accessing trading or wallet functionality. The customer identification program (CIP) collects and verifies the following information at minimum:

• Legal name as it appears on government-issued identification
• Date of birth
• Residential address
• Government-issued identification document number

Identity information is verified against independent sources. All customers are screened against the Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list and other applicable sanctions lists at the time of onboarding and on an ongoing basis.

Enhanced due diligence may be applied to customers presenting higher risk indicators, including those with complex transaction patterns, high transaction volumes, or connections to higher-risk jurisdictions.

Automated transaction monitoring systems review activity across all accounts for indicators of potential money laundering, structuring, or other financial crimes. Monitoring rules are calibrated to the risk profile of the platform's customer base and transaction types.

Alerts generated by the monitoring system are reviewed by compliance personnel. Alerts that cannot be resolved through review of account information and transaction history are escalated for further investigation. Investigations are documented and retained as part of the compliance record.

Monitoring parameters are reviewed periodically and adjusted to reflect changes in transaction patterns, regulatory guidance, and known typologies for financial crime involving digital assets.

DIRE MONEY TRANSMITTER LLC files Suspicious Activity Reports (SARs) with FinCEN when a transaction involves funds derived from illegal activity, is designed to evade BSA reporting requirements, lacks a lawful purpose, or otherwise raises concerns that cannot be resolved through investigation.

SAR filings are confidential under federal law. Customers are not notified when a SAR has been filed. The existence of a SAR filing, or the fact that a SAR has been considered, is not disclosed to the subject of the report.

Currency Transaction Reports (CTRs) are filed for cash transactions exceeding applicable thresholds as required by 31 CFR 1022.310. The platform does not facilitate structuring of transactions to avoid reporting requirements, and accounts showing structuring patterns are subject to immediate review.

Transaction records are retained for the periods required by applicable BSA regulations. At minimum, records of transmittals of funds are retained for five years from the date of the transaction. Customer identification records are retained for five years following the closure of the account.

Records are maintained in a format that allows retrieval within a reasonable time upon request by FinCEN or other authorized regulatory authorities. The company cooperates fully with lawful regulatory examinations and information requests.

All employees with responsibilities related to customer onboarding, transaction processing, or compliance receive AML training appropriate to their role. Training covers the requirements of the Bank Secrecy Act, recognition of suspicious activity indicators, the company's internal reporting procedures, and the consequences of non-compliance.

Training is conducted at onboarding for new employees and updated periodically to reflect changes in regulatory requirements and emerging financial crime typologies. Training completion is documented and retained.

The AML program is subject to independent testing on a periodic basis. Independent testing evaluates the adequacy of the program's policies and procedures, the effectiveness of transaction monitoring, the completeness of customer identification records, and the accuracy of regulatory filings.

Findings from independent testing are reported to senior management. Deficiencies identified through testing are addressed through documented corrective action. Testing results and corrective action records are retained as part of the compliance program documentation.