Política AML/KYC y Cumplimiento

Ayni Token Inc. ("Ayni Gold", "we", "us", or "our") is committed to maintaining a secure, transparent, and compliant platform for users who access our services, including AYNI tokens, Gold Mining Units, staking, marketplace functionality, withdrawals, external wallet transfers, and other related features.

This AML/KYC & Compliance Policy explains our approach to anti-money laundering, counter-terrorist financing, sanctions compliance, identity verification, source of funds checks, restricted jurisdictions, non-custodial wallet access, and related compliance procedures.

This Policy should be read together with our Terms of Use and Privacy Policy.

The Services are intended only for users who are at least 18 years old and have full legal capacity to enter into binding agreements under the laws applicable to them.

Ayni Gold may refuse, suspend, or terminate access where a user is under 18, lacks legal capacity, provides inaccurate age or identity information, or is otherwise not eligible to use the Services.

Ayni Gold applies a risk-based approach to compliance. This means that the level of verification, monitoring, and documentation required may depend on the user, transaction type, jurisdiction, payment method, wallet activity, transaction size, source of funds, source of wealth, and other risk factors.

We may conduct checks before, during, or after a user accesses certain services. These checks are designed to help prevent fraud, money laundering, terrorist financing, sanctions evasion, unauthorized activity, and other unlawful or prohibited conduct.

Ayni Gold may re-verify users, refresh customer information, request updated documents, or conduct additional due diligence at any time where required by law, internal policy, risk profile, transaction activity, provider requirements, or changes in user information.

Ayni Gold is not a bank, deposit-taking institution, broker-dealer, investment firm, fiduciary, trustee, or regulated custodian, and does not provide regulated custody services unless expressly stated otherwise in separate written terms.

Where digital wallet functionality is made available, the platform is designed to use non-custodial or self-custodial wallet infrastructure supported by third-party wallet infrastructure providers. Ayni Gold does not treat user token balances or Gold Mining Unit positions as bank deposits or custodial assets held for users.

Users are responsible for ensuring that they understand how wallet access, external wallet transfers, on-chain transactions, and private key or account recovery mechanisms work before using the Services. Certain wallet, smart contract, blockchain, and external transfer operations may be irreversible.

Ayni Gold may use operational, treasury, settlement, smart contract, or multisignature wallets for platform operations, payment settlement, treasury management, or security purposes. Such operational infrastructure does not make Ayni Gold a regulated custodian of user assets unless expressly required by applicable law.

Ayni Gold may require users to complete identity verification before allowing access to certain services, including but not limited to:

• purchasing AYNI tokens;
• purchasing Gold Mining Units;
• withdrawing or externalising AYNI tokens or Gold Mining Units to an external wallet;
• using secondary marketplace functionality;
• receiving certain rewards or distributions;
• increasing transaction limits;
• accessing features that require enhanced compliance review.

Identity verification is performed through third-party verification providers, including Sumsub. The same provider is used for verification at the point of purchase and for verification carried out directly through the Ayni Gold platform.

Users may be asked to provide information or documents such as:

• full legal name;
• date and place of birth;
• nationality and citizenship;
• residential or business address;
• proof of address;
• identity documents;
• verification photos or selfies;
• wallet addresses;
• information about AYNI tokens or Gold Mining Units held;
• source of funds or source of tokens;
• other information reasonably required for AML/CFT, sanctions compliance, fraud prevention, or risk management purposes.

Users may be able to access certain platform features without completing platform-level KYC. However, Ayni Gold may restrict withdrawals, external wallet transfers, externalisation of AYNI tokens or Gold Mining Units, marketplace activity, or other features until the user has successfully completed the required verification.

Purchases of AYNI tokens or Gold Mining Units require KYC verification. Withdrawal or externalisation to an external wallet also requires platform-level KYC through Sumsub.

Ayni Gold may refuse, delay, suspend, or limit withdrawals or transfers where:

• the user has not completed required KYC;
• additional verification is required;
• transaction activity appears suspicious or inconsistent;
• the wallet address presents elevated risk;
• the user is located in or connected to a restricted jurisdiction;
• the user is subject to sanctions or other restrictions;
• required information is incomplete, inaccurate, outdated, or misleading;
• Ayni Gold is required or advised to do so by law, regulation, compliance policy, payment provider, banking partner, compliance vendor, wallet infrastructure provider, or law enforcement request.

Ayni Gold may conduct anti-money laundering and counter-terrorist financing checks on users, transactions, counterparties, wallets, and activity connected to our services.

These checks may include:

• identity verification;
• sanctions screening;
• politically exposed person screening;
• adverse media checks;
• source of funds checks;
• source of wealth checks;
• wallet address review and risk screening through a dedicated blockchain analytics provider, where applicable;
• blockchain transaction review and monitoring through a dedicated blockchain analytics provider, where applicable;
• review of transaction patterns;
• review of payment activity;
• review of documents and supporting information;
• enhanced due diligence where appropriate.

Important: Sumsub is used for identity verification and related KYC/AML checks. On-chain wallet and blockchain transaction screening, where used, is performed through a separate blockchain analytics provider. The specific provider should be reflected in the Privacy Policy and vendor list once confirmed and activated.

Ayni Gold is responsible for verifying user identity for AML/CFT purposes and may identify individuals or legal entities with whom it establishes or intends to establish business relationships or transactions.

For legal entities, Ayni Gold may also take reasonable steps to verify beneficial owners, including main investors, controllers, directors, shareholders, authorized representatives, or fund managers.

Where a user is a company, fund, trust, partnership, or other legal entity, Ayni Gold may request additional information and documentation, including:

• certificate of incorporation or equivalent document;
• constitutional documents;
• register of directors;
• register of shareholders or members;
• ownership and control structure;
• ultimate beneficial owner information;
• proof of authority of the person acting on behalf of the entity;
• source of funds and source of wealth information;
• business activity description;
• supporting contracts, invoices, bank statements, financial statements, or other documents.

Ayni Gold may refuse or restrict access where beneficial ownership, control, authority, source of funds, or source of wealth cannot be reasonably verified.

Ayni Gold does not intend to provide services to persons, entities, wallets, counterparties, or jurisdictions that are subject to applicable sanctions, embargoes, or legal restrictions.

Users must not use our services if they are:

• subject to sanctions;
• acting on behalf of a sanctioned person or entity;
• owned or controlled by a sanctioned person or entity;
• located in, incorporated in, resident in, or operating from a restricted jurisdiction;
• using funds, assets, wallets, or payment methods connected to illegal activity;
• attempting to bypass compliance controls, sanctions, or geographic restrictions.

Ayni Gold may screen users and transactions against sanctions lists and other compliance databases. We may refuse onboarding, suspend accounts, block transactions, restrict withdrawals, freeze access where legally required, or terminate services if sanctions or restricted-jurisdiction risks are identified.

Ayni Gold does not provide services to users, entities, wallets, counterparties, or beneficial owners located in, incorporated in, resident in, operating from, or otherwise connected to jurisdictions that are subject to comprehensive sanctions, high-risk restrictions, or internal compliance limitations.

For the purposes of this Policy, Restricted Jurisdictions may include, but are not limited to:

• Iran;
• North Korea;
• Cuba;
• Syria;
• Afghanistan;
• Myanmar;
• Venezuela;
• Sudan;
• South Sudan;
• Yemen;
• Somalia;
• Democratic Republic of the Congo;
• Central African Republic;
• Libya;
• Iraq;
• Lebanon;
• Zimbabwe;
• Crimea;
• Donetsk;
• Luhansk;
• Zaporizhzhia;
• Kherson;
• any other territory subject to comprehensive sanctions, embargoes, or equivalent restrictions under applicable sanctions regimes.

Ayni Gold may also restrict access for users connected to jurisdictions listed by the Financial Action Task Force as high-risk or subject to increased monitoring, as well as jurisdictions restricted by our payment providers, banking partners, compliance vendors, wallet infrastructure providers, or internal risk policy.

Ayni Gold may refuse onboarding, suspend accounts, restrict platform access, block purchases, prevent withdrawals, prevent external wallet transfers, cancel pending transactions where technically possible, or terminate services where a user or transaction is connected to a Restricted Jurisdiction.

Users must not attempt to access or use the Services through VPNs, proxies, nominee arrangements, false information, third-party accounts, shell entities, or any other method intended to bypass geographic, sanctions, KYC, AML, or compliance restrictions.

Ayni Gold may update the list of Restricted Jurisdictions at any time without prior notice where required by law, sanctions changes, payment provider requirements, banking partner requirements, compliance vendor requirements, internal risk policy, or other applicable restrictions.

Ayni Gold may request source of funds or source of wealth information where required by law, internal policy, payment provider requirements, banking partner requirements, transaction size, risk profile, or unusual activity.

Acceptable supporting documents may include:

• bank statements;
• proof of income;
• sale agreements;
• investment statements;
• company financial records;
• tax documents;
• inheritance documents;
• mining, trading, or crypto transaction records;
• wallet transaction history;
• other documents reasonably required to verify the origin of funds.

Failure to provide satisfactory information may result in refusal, delay, suspension, withdrawal restriction, transaction cancellation where technically possible, or account termination.

Ayni Gold may monitor user activity and transactions to detect suspicious behavior, fraud, abuse, sanctions exposure, or other compliance risks.

Monitoring may include activity related to:

• purchases;
• staking;
• rewards;
• withdrawals;
• external wallet transfers;
• marketplace listings and purchases;
• on-chain transactions;
• wallet balances;
• unusual transaction patterns;
• multiple accounts;
• suspicious payment activity.

Where on-chain screening is used, Ayni Gold uses or may use a dedicated blockchain analytics provider separate from Sumsub to assess wallet addresses, transaction exposure, sanctions indicators, illicit finance typologies, and other blockchain-related risk factors.

Certain blockchain transactions are public, permanent, and outside Ayni Gold’s control. Where Ayni Gold can link a wallet address to a verified user, that combined information is treated as personal data in accordance with our Privacy Policy. The underlying on-chain records themselves remain public and outside Ayni Gold’s control.

Ayni Gold intends to maintain internal compliance governance appropriate to the nature, scale, and risk profile of its business.

Ayni Gold may designate a compliance lead, money laundering reporting officer, or equivalent responsible person where required by applicable law, provider requirements, banking partner requirements, or internal risk policy.

Ayni Gold may maintain an internal suspicious-activity escalation process under which employees, contractors, support agents, operations personnel, and relevant service providers may escalate unusual or suspicious activity for review.

Escalated matters may be reviewed for potential account restriction, enhanced due diligence, transaction delay, transaction rejection, provider notification, legal review, or reporting to competent authorities where required or permitted by law.

Ayni Gold is not required to notify users where doing so would be unlawful, prohibited, or inconsistent with compliance obligations or internal investigation requirements.

Ayni Gold may refuse, suspend, restrict, or terminate access to all or part of the services where we reasonably determine that:

• a user has failed KYC or AML checks;
• a user has provided false, incomplete, misleading, or outdated information;
• a user refuses to provide requested documents;
• a user presents unacceptable compliance, fraud, legal, regulatory, reputational, or operational risk;
• activity appears suspicious, abusive, unlawful, or inconsistent with the user’s profile;
• the user is subject to sanctions or connected to a restricted jurisdiction;
• the user attempts to bypass compliance controls;
• required by applicable law, regulation, internal policy, court order, regulator, law enforcement authority, payment provider, banking partner, compliance vendor, wallet infrastructure provider, or other service provider.

Ayni Gold may also delay, block, or reject transactions where compliance review is pending.

Where required or permitted by law, Ayni Gold may report suspicious activity, attempted fraud, sanctions exposure, or other unlawful conduct to relevant authorities, regulators, law enforcement agencies, payment providers, banking partners, compliance vendors, or other relevant service providers.

Ayni Gold is not required to notify users where doing so would be unlawful, prohibited, or inconsistent with compliance obligations.

Ayni Gold may use trusted third-party service providers to support compliance, identity verification, payments, wallet infrastructure, fraud prevention, analytics, hosting, and security.

Current providers may include Sumsub for KYC/AML, Alchemy Pay and Banxa for payment processing and related payment compliance, Turnkey for user wallet infrastructure, and Gnosis Safe for treasury/multisignature infrastructure.

Ayni Gold may also use a dedicated blockchain analytics provider for wallet risk screening and on-chain transaction review. This provider is separate from Sumsub and should be identified in the Privacy Policy and vendor list once confirmed.

Third-party providers may process user information in accordance with their own policies and applicable laws. Ayni Gold may share information with such providers where necessary to operate the services, process transactions, verify identity, prevent fraud, comply with law, or enforce our terms and policies.

Ayni Gold may retain KYC/AML records, transaction records, account information, compliance reviews, and supporting documentation for as long as required or permitted by applicable law.

KYC/AML records may be retained for up to 10 years after the end of the business relationship where permitted by applicable law and justified by Ayni Gold’s AML/CFT, sanctions, fraud prevention, dispute resolution, legal, accounting, or regulatory obligations.

For users in jurisdictions where a shorter or different retention period is required, Ayni Gold may apply the applicable legal requirement. Ayni Gold may also delete, anonymize, or aggregate information where retention is no longer necessary or permitted.

The 10-year retention period is a deliberate compliance and risk-management position and should be periodically reviewed against applicable BVI, EU/UK, payment-provider, banking-partner, and product-specific requirements.

Users agree to:

• provide accurate, complete, and up-to-date information;
• complete required KYC and AML checks when requested;
• provide additional documents when reasonably required;
• use only lawful funds and assets;
• not use the services for money laundering, terrorist financing, sanctions evasion, fraud, market abuse, or other unlawful activity;
• not act on behalf of another person unless properly authorized and disclosed;
• notify Ayni Gold of material changes to their information;
• comply with all applicable laws and regulations.

Completion of KYC or submission of documents does not guarantee onboarding, transaction approval, withdrawal approval, access to all services, or continued access to the platform.

Ayni Gold retains discretion to determine whether a user, transaction, wallet, jurisdiction, or activity is acceptable under its compliance standards.

Ayni Gold may update this AML/KYC & Compliance Policy from time to time to reflect changes in our services, legal requirements, regulatory expectations, provider requirements, internal procedures, risk controls, or third-party provider arrangements.

The latest version will be made available through our website or application.

For questions about this Policy or our compliance procedures, please contact:

compliance@ayni.gold