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Compliance

Anti-Money Laundering Policy

Last updated: April 9, 2026. Zome Wallet is committed to preventing money laundering, terrorist financing, and all forms of financial crime. This policy outlines our compliance framework and obligations.

Prevention

We maintain robust controls to detect and prevent our platform from being used for money laundering, fraud, or the financing of illegal activities.

Detection

We implement real-time transaction monitoring and risk scoring to identify suspicious patterns and report them to the relevant authorities as required by law.

Compliance

We comply with all applicable AML laws and regulations in the jurisdictions in which we operate, and we cooperate fully with regulatory authorities.

1. Purpose and Scope

This Anti-Money Laundering (AML) Policy applies to all users of Zome Wallet and governs our approach to preventing money laundering (ML), terrorist financing (TF), and other financial crimes. It is designed to comply with applicable AML/CFT (Combating the Financing of Terrorism) regulations.

2. Definitions

  • Money Laundering: the process of concealing the origins of illegally obtained funds by passing them through a complex sequence of banking transfers or commercial transactions
  • Terrorist Financing: providing financial support to individuals or groups planning or engaged in terrorism
  • KYC (Know Your Customer): the process of verifying the identity of users
  • Suspicious Activity: any transaction or behavior that may indicate potential involvement in financial crime

3. Know Your Customer (KYC)

Zome Wallet applies a risk-based approach to customer due diligence. Depending on the features accessed and transaction volumes, users may be required to complete identity verification, which may include:

  • Government-issued photo identification (passport, national ID, or driver's license)
  • Proof of address (utility bill or bank statement, not older than 3 months)
  • Selfie or liveness check for biometric verification
  • Source of funds declaration for high-value transactions

We use trusted, industry-standard third-party KYC providers to process identity documents securely. All data is handled in accordance with our Privacy Policy.

4. Prohibited Activities

The following activities are strictly prohibited on Zome Wallet:

  • Using Zome Wallet to launder proceeds from criminal activity
  • Structuring transactions to evade reporting thresholds ("smurfing")
  • Conducting transactions on behalf of sanctioned individuals or entities
  • Using Zome Wallet for the financing of terrorism or proliferation
  • Providing false or misleading information during KYC verification
  • Using multiple accounts to circumvent transaction limits or compliance controls

5. Transaction Monitoring

We employ automated transaction monitoring systems that analyze on-chain activity in real time. Our systems flag and review transactions that exhibit risk indicators such as:

  • Unusually large or rapid transactions inconsistent with a user's profile
  • Transactions to or from addresses associated with illicit activity
  • Patterns suggestive of layering or structuring
  • Use of high-risk mixing services or privacy protocols for the purpose of obfuscation

6. Sanctions Compliance

Zome Wallet screens all users and transactions against applicable sanctions lists, including those maintained by OFAC (U.S. Office of Foreign Assets Control), the UN Security Council, the EU, and other relevant authorities. Users or transactions matched against sanctions lists will be blocked and reported as required by law.

7. Reporting Obligations

Where required by applicable law, Zome Wallet will file:

  • Suspicious Activity Reports (SARs) with the relevant financial intelligence unit
  • Currency Transaction Reports (CTRs) for transactions above applicable thresholds

Users are advised that tipping off — i.e., notifying a subject that they are the target of an investigation — is a criminal offense in many jurisdictions.

8. Record Keeping

We retain KYC records, transaction records, and compliance documentation for a minimum of five (5) years from the end of the business relationship, or longer if required by law. All records are stored securely and protected against unauthorized access.

9. Training and Awareness

All Zome Wallet team members with compliance responsibilities receive regular AML training. We maintain internal procedures and appoint a designated Compliance Officer responsible for overseeing our AML program.

10. User Obligations

By using Zome Wallet, you agree to:

  • Provide accurate and complete information during KYC verification
  • Use the platform only for lawful purposes
  • Cooperate with any compliance review or identity verification request
  • Promptly report any suspected financial crime or compliance breach to us

11. Enforcement

Violations of this AML Policy may result in immediate account suspension, termination of services, forfeiture of assets as permitted by law, and reporting to law enforcement or regulatory authorities. We reserve the right to refuse service to any user at our discretion for compliance reasons.

12. Contact

For compliance-related inquiries or to report suspicious activity, contact our Compliance team at:
contact@zomewallet.com
343 504-2112
WhatsApp: 343 504-2112