Anti-Money Laundering Policy

1. Introduction and Purpose

IOI is committed to maintaining the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our approach to preventing the use of our services for money laundering, terrorist financing, or other financial crimes.

We are committed to complying with all applicable AML/CTF laws and regulations in the jurisdictions where we operate.

2. Scope

This policy applies to:

• All users of the IOI application and services
• All operations and transactions processed through IOI

3. Risk-Based Approach

IOI employs a risk-based approach to AML/CTF compliance. We assess and mitigate risks based on:

• User geography and jurisdiction
• Transaction patterns and volumes
• Source of funds indicators
• Nature of trading activity

4. Know Your Customer (KYC)

4.1 User Verification

IOI operates as a software service that connects to users' existing Binance accounts. As such:

• Users must have a verified Binance account to use IOI
• Binance performs KYC verification as part of their onboarding process
• We rely on Binance's KYC procedures as a foundational layer

4.2 Additional Verification

IOI may require additional verification for:

• High-value subscription tiers
• Users flagged by our monitoring systems
• Users in higher-risk jurisdictions
• Any user upon reasonable suspicion of illicit activity

5. Transaction Monitoring

We implement automated monitoring systems to detect suspicious activity, including:

• Unusual trading patterns or volumes
• Rapid movement of funds
• Structured transactions designed to avoid thresholds
• Activity inconsistent with user profile
• Connections to high-risk addresses or entities

6. Suspicious Activity Reporting

When suspicious activity is detected:

• The activity is reviewed by our compliance team
• We may request additional information from the user
• Suspicious Activity Reports (SARs) are filed with relevant authorities as required by law
• We do not inform users when a SAR has been filed (tipping off is prohibited)

7. Prohibited Activities

The following activities are strictly prohibited:

• Using IOI to launder money or proceeds of crime
• Financing terrorism or terrorist organizations
• Evading sanctions or trading with sanctioned entities
• Structuring transactions to avoid reporting requirements
• Using false or misleading identity information
• Operating on behalf of undisclosed third parties

8. Sanctions Compliance

IOI complies with international sanctions regimes, including:

• US Office of Foreign Assets Control (OFAC) sanctions
• European Union sanctions
• United Nations sanctions
• Other applicable national sanctions programs

Users from sanctioned countries or regions are prohibited from using our services. We screen users against sanctions lists and deny service to any matches.

9. Record Keeping

We maintain records as required by applicable law, including:

• User registration and verification data
• Transaction records
• Suspicious activity reports and investigations
• Compliance training records

Records are retained for a minimum of 5 years after the end of the business relationship or longer as required by law.

10. Ongoing Monitoring

IOI maintains ongoing compliance monitoring including:

• Regular review of AML/CTF procedures
• Updates based on regulatory changes
• Continuous improvement of detection systems

11. User Cooperation

By using IOI, you agree to:

• Provide accurate and truthful information
• Respond promptly to verification requests
• Not use our services for any illegal purposes
• Report any suspicious activity you become aware of
• Cooperate with any investigations

12. Consequences of Non-Compliance

Violations of this policy may result in:

• Immediate suspension or termination of services
• Reporting to relevant authorities
• Freezing of funds pending investigation
• Legal action

13. Compliance Responsibility

IOI maintains compliance oversight responsible for:

• Implementing and maintaining this AML policy
• Reviewing suspicious activity reports
• Filing required reports with authorities
• Updating policies to reflect regulatory changes

14. Policy Review

This policy is reviewed at least annually and updated as necessary to reflect:

• Changes in applicable laws and regulations
• Updates to international standards
• New money laundering techniques or risks
• Findings from internal audits

15. Contact

For questions about our AML policy or to report suspicious activity:

Email: compliance@getioi.app