DMaple AML, KYC/KYB & Compliance Statement

Effective Date: July 20, 2026
Company: DMaple Inc.

This Statement applies to DMaple websites, applications, product interfaces and related online services. It is written for public disclosure and is not an internal AML compliance program or procedure manual.

1. Purpose

This AML, KYC/KYB & Compliance Statement (the “Statement”) explains how DMaple Inc. (“DMaple,” “we,” “us,” or “our”) may apply anti-money laundering, anti-terrorist financing, sanctions, identity verification, business verification and related compliance controls in connection with the DMaple websites, applications, product interfaces, tools and services (the “Services”).

It is a public explanatory document and does not describe DMaple’s confidential internal compliance program, operational procedures, partner due diligence files or risk-control methods.

This Statement should be read together with our Terms of Service, Privacy Policy, Cookie Policy, Non-Custodial Statement, Risk Disclosure and any product-specific terms or notices that apply to a particular Service.

2. Key Points

- DMaple Inc. is registered as a Money Services Business with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under registration number C100001133. FINTRAC registration does not indicate that FINTRAC endorses, sponsors, approves, recommends or licenses DMaple or the DMaple Platform.

- Some Services may be available only after identity verification, business verification, sanctions screening, wallet screening, transaction review, Travel Rule-related information collection, partner review or other checks are completed.

- DMaple may collect and verify information about individuals, businesses, beneficial owners, directors, officers, authorized users, wallets, counterparties, recipients, beneficiaries, payment purposes, source of funds, source of wealth, expected activity, supported routes and transaction details where required or appropriate.

- DMaple may delay, reject, restrict, suspend, place on hold or decline access to a Service, route, transaction request, payout method, wallet flow, account or user where required by law, sanctions requirements, partner requirements, compliance review, risk-based controls, technical limitations or applicable terms.

- DMaple’s non-custodial design does not remove or reduce applicable AML/ATF, sanctions, recordkeeping, reporting, privacy, partner or risk-management obligations.

- DMaple does not disclose public details of confidential internal compliance controls, screening logic, investigation methods or escalation procedures.

3. Regulatory Status and Compliance Approach

DMaple’s compliance framework is designed to support applicable Canadian AML/ATF, sanctions, recordkeeping, reporting and privacy requirements, as well as partner, banking, payment, digital asset and settlement route requirements that may apply to specific Services.

DMaple applies a risk-based approach. The information and checks required for a user, business, wallet, transaction, payment route or feature may vary based on factors such as client type, business activity, transaction purpose, asset type, payment method, payout route, jurisdiction, counterparty, wallet characteristics, partner requirements and other risk or legal considerations.

DMaple may apply checks before onboarding, before enabling a feature, before processing a transaction request, before approving a payout or settlement route, during ongoing monitoring, or when activity changes in a way that requires additional review.

4. When Verification May Be Required

Some limited informational, pre-onboarding or interface features may be available without full verification where legally and operationally permitted. Transaction flows, business features, payout routes, fiat routes, conversion routes, external transfers, partner-supported features, higher-risk features and other product scenarios may require KYC, KYB, sanctions screening, wallet screening, transaction monitoring, partner review, enhanced due diligence or DMaple approval.

DMaple may request verification or additional information when required by law, where required by an approved partner or payment route, where a transaction or wallet requires review, where a user or business changes activity, where information becomes outdated or incomplete, or where DMaple determines that additional review is appropriate.

DMaple may decline to provide or continue a Service if required information is not provided, cannot be verified, is inaccurate or incomplete, appears inconsistent with expected activity, or raises legal, sanctions, fraud, AML/ATF, partner, jurisdictional, technical or risk concerns.

5. Individual KYC

For individual users, DMaple may request information and documents to identify and verify the user, assess eligibility, understand expected activity and comply with legal, partner and risk requirements. The information requested may depend on the Service, feature, jurisdiction, transaction type, wallet flow and risk review.

Information may include, where required or appropriate:

- name, date of birth, residential address, email address, telephone number and account information;

- government-issued identification documents, document numbers, expiry dates and related verification information;

- selfie, liveness, biometric or document-authentication information where supported by a verification provider and permitted by applicable law;

- occupation, nature of principal business, employer or business activity;

- country of residence, nationality or other jurisdictional information where relevant;

- source of funds, source of wealth, expected activity, transaction purpose, payment purpose or supporting documents;

- wallet addresses, blockchain networks, account details, recipient or beneficiary information and transaction-related information;

- politically exposed person, head of international organization, sanctions, adverse media or other risk-related information where applicable.

DMaple does not collect every category of information from every individual. The information requested may vary depending on legal requirements, product access, supported routes, partner requirements and risk review.

6. Business KYB

For business users, DMaple may request business verification information to understand the business, confirm authority to use the Services, identify relevant persons and assess the business activity, transaction purpose and supported payment routes.

Business verification may include, where required or appropriate:

- legal name, trade name, registered address, operating address, website, industry, business activity and business contact information;

- incorporation, registration, formation, tax, business number or similar documents and records;

- ownership and control information, including beneficial owners, controlling persons and ownership structure;

- directors, officers, authorized representatives, authorized users and account administrators;

- proof of authority for the person using or administering the DMaple account on behalf of the business;

- business model, expected transaction activity, countries of operation, payment routes, payout destinations, invoices, contracts or customer/supplier relationships;

- source of funds, source of wealth, financial information or supporting documents where required or appropriate;

- bank account, payout account, wallet, counterparty, recipient, beneficiary and route-related information.

DMaple may require updates to business information where ownership, control, authorized users, activity, transaction patterns, jurisdictions, counterparties or supported routes change.

7. Wallet, Transaction and Route Checks

DMaple may conduct wallet screening, blockchain analytics, sanctions screening, transaction monitoring, route review, partner review and other checks before or after a transaction request is submitted, depending on the Service and transaction flow.

Checks may relate to wallet addresses, blockchain networks, digital assets, fiat currencies, senders, recipients, beneficiaries, counterparties, bank accounts, payout accounts, invoices, payment purposes, transaction paths, supported jurisdictions and partner-supported routes.

DMaple may request additional information or supporting documents relating to a transaction, payment, invoice, wallet, counterparty, recipient, beneficiary, bank account, payout method, source of funds, source of wealth, business relationship or payment purpose.

DMaple does not guarantee that any particular transaction, asset, currency, wallet, bank account, payout account, recipient, beneficiary, jurisdiction, partner, payment route or settlement method will be supported or available.

8. Sanctions, Restricted Parties and Prohibited Use

DMaple does not knowingly support Services, routes, transactions or account relationships involving sanctioned persons, sanctioned entities, prohibited jurisdictions, restricted jurisdictions, blocked wallets, prohibited counterparties, prohibited transaction paths or other activity that DMaple is required or permitted to restrict under applicable law, sanctions requirements, partner requirements or risk-based controls.

You must not use the Services for illegal activity, fraud, money laundering, terrorist financing, sanctions evasion, ransomware, scams, stolen funds, trafficking, exploitation, market manipulation, unauthorized financial activity, deceptive activity, or activity intended to hide the true sender, recipient, beneficiary, owner, controller, source of funds, source of wealth or purpose of a transaction.

DMaple may block, reject, restrict, suspend, freeze where required and possible, report or otherwise handle activity in accordance with applicable law, sanctions requirements, partner requirements, DMaple procedures and applicable terms.

9. Travel Rule and Transfer Information

Certain Services, transactions, assets, payment routes or partner-supported flows may require DMaple to collect, verify, transmit, receive, retain or share transfer-related information for Travel Rule, recordkeeping, reporting, partner, sanctions, wallet screening or other compliance purposes.

This information may include sender, recipient, beneficiary, payer, payee, wallet, account, address, transaction, payment purpose, invoice or business relationship information, depending on the relevant Service, transaction flow, route, jurisdiction, partner requirements and applicable law.

A transaction or route may be delayed, rejected, restricted or made unavailable if required Travel Rule-related or transfer-related information is missing, inaccurate, incomplete, inconsistent, cannot be verified, or cannot be transmitted or received through an approved route.

10. Information Accuracy, Additional Requests and Restrictions

You are responsible for providing accurate, complete, current and non-misleading information to DMaple. You must promptly update information that becomes inaccurate, incomplete or outdated.

DMaple may request additional information or documents at onboarding, before enabling a Service, before or after a transaction request, during ongoing monitoring, after a change in activity, in response to a partner request, or where required by law, sanctions requirements, compliance review or risk-based controls.

If information is not provided, cannot be verified, is inaccurate or incomplete, appears inconsistent with expected activity, or raises legal, AML/ATF, sanctions, fraud, partner, jurisdictional, technical or risk concerns, DMaple may refuse onboarding, restrict features, delay or reject transaction requests, suspend or terminate access, close an account, refuse a payout method or decline to support a route.

11. Records, Reporting and Privacy

DMaple may create and retain records relating to accounts, onboarding, KYC, KYB, beneficial ownership, authorized users, wallet screening, transaction monitoring, payment activity, Service Credits, fees, compliance reviews, Travel Rule checks, restrictions, refusals, investigations, communications, complaints and other matters.

DMaple retains records for as long as reasonably necessary for the purposes described in this Statement, the Privacy Policy and the Terms of Service, and as required or permitted by applicable law, regulatory obligations, audit requirements, partner requirements, dispute resolution, fraud prevention, security, accounting, tax, reporting or legitimate business purposes.

DMaple may share information with identity verification providers, business verification providers, sanctions screening providers, blockchain analytics providers, payment service providers, banking partners, payout providers, settlement partners, digital asset service providers, professional advisers, auditors, regulators, law enforcement, courts, government authorities and other parties where required or permitted by law, where necessary to provide or protect the Services, or where described in the Privacy Policy.

DMaple may submit reports or information to FINTRAC or other competent authorities where required or permitted by applicable law. DMaple may be prohibited from notifying a user or business about certain reports, reviews, restrictions, investigations or disclosures.

12. Non-Custodial Model

The DMaple Platform is designed to operate on a non-custodial basis. DMaple does not take custody of client digital assets on behalf of users, hold users’ private keys, seed phrases or recovery phrases, or maintain client deposit accounts or stored-value balances.

Compliance checks, verification, sanctions controls, wallet screening, partner review, transaction restrictions or route restrictions do not by themselves mean that DMaple is acting as a custodian of client assets. They mean that access to DMaple Services and supported routes may be subject to legal, compliance, partner, operational and risk requirements.

Users are responsible for wallets they own or control, including private keys, seed phrases, recovery phrases, wallet credentials, wallet addresses, blockchain networks, tokens, transaction amounts and recipient information.

13. Relationship to Other Documents

This Statement is a public explanatory document. It does not replace the Terms of Service, Privacy Policy, Non-Custodial Statement, Risk Disclosure, Cookie Policy, any applicable product terms, or any separate agreement between you and DMaple.

If there is a conflict between this Statement and the Terms of Service or a separate written agreement with DMaple, the Terms of Service or that written agreement will apply to the extent of the conflict.

14. Changes to This Statement

DMaple may update this Statement from time to time to reflect changes in our Services, product design, supported routes, partner arrangements, legal requirements, compliance practices, privacy practices or business operations. The Effective Date above shows when this Statement was last updated. Material changes will be communicated where required by applicable law.

15. Contact Us

If you have questions about this Statement or DMaple’s AML, KYC/KYB or compliance approach, please contact us at:

DMaple Inc.
Email: legal@dmaple.com
Attention: Privacy & Compliance Contact