1. Introduction
This Anti-Money Laundering (AML) Policy is designed by Send Crypto Just Like That, Inc. to ensure compliance with all applicable laws and regulations related to the prevention of money laundering and terrorist financing. This AML Policy sets out the internal controls and monitoring practices adopted to detect and deter money laundering, terrorist financing, and other forms of financial crime. **The Policy is aimed at protecting the company from using its services for illegal activities.**Though DMaple operates as a non-custodial platform, we voluntarily implement monitoring and reporting mechanisms in alignment with industry best practices.
Policy objectives
- Ensuring compliance with AML legislation.
- Protecting the company's reputation.
- Ensuring effective monitoring and control of financial transactions.
- Employee training on KYC and AML issues.
Scope of application
- This policy applies to all employees of the company, as well as to any third parties working on behalf of the company.
2. Legal Background
As a Canadian-registered non-custodial technology provider, we are not presently required to register as an MSB under FINTRAC. However, we recognize our role in protecting the ecosystem from misuse and act in accordance with FATF recommendations and Canadian compliance standards.
3. Our Business Model — Non-Custodial Infrastructure
DMaple never holds or controls customer funds. Users retain full custody of private keys. We facilitate transactions but do not initiate, approve, or reverse them.
4. Risk Assessment Methodology
We implement a dynamic risk-based approach to detect abnormal activity.
Factors include:
- Frequency of transactions;
- Use of identical sending or receiving addresses;
- Volume spikes or bursts;
- Behavioral anomalies (IP shifts, rapid login sessions).
Flagged behavior is logged and analyzed by the Compliance Officer for escalation. Based on the data obtained, clients are classified by risk levels (low, medium, high) based on various factors (geographical location, type of business, etc.).
5. Transaction Monitoring
A real-time backend interface (secured and accessible only to the AML Officer) tracks:
- Patterns of suspicious activity;
- High-frequency or round-trip transactions;
- Unusual timing or routing behavior;
- Sudden onboarding of business accounts with minimal history.
This system is continuously updated with additional red flags and adjusted based on emerging typologies.
6. Red Flags
Examples of behavior that may trigger alerts include:
- Use of blacklisted or sanctioned addresses;
- Repeat transactions between unrelated users;
- Use of the same identification data or documents by two or more persons;
- Use of multiple identity documents by one person;
- Connections to jurisdictions under FATF enhanced monitoring;
- Use of anonymizing tools (e.g., Tor, VPN with inconsistent IP regions);
- Receipt of funds followed by immediate forwarding.
7. Reporting Obligations
All DMaple employees are required to report any suspicious transactions or activities in accordance with established procedures. Reports of suspicious activity should be sent to the designated unit for further analysis and, if necessary, notification to the relevant authorities.
8. Roles and Responsibilities
Daria Kuteva has been appointed as DMaple’s internal AML Officer. She is responsible for:
- Reviewing system alerts;
- Maintaining updated risk indicators;
- Coordinating internal reviews and documentation;
- Serving as point of contact with external authorities if needed.
9. Employee Training
As of this version, only the AML Officer has completed formal training. An internal training program is being developed to onboard other staff into basic compliance principles, with periodic refreshers to be introduced.
10. Policy Review
CycleThis policy is reviewed and updated upon:
- Addition of fiat payment features;
- Onboarding of new jurisdictions or partners;
- Any material regulatory changes.