AML / KYC Policy

Last updated: April 24, 2026

This Anti-Money-Laundering (AML) and Know-Your-Customer (KYC) Policy summarizes the program Zula LLC, operating as Zula LLC ("Zula", "we", "us", "our"), maintains in connection with our digital asset services. The program is designed to comply with the Bank Secrecy Act (BSA), implementing regulations of the Financial Crimes Enforcement Network (FinCEN), applicable U.S. Office of Foreign Assets Control (OFAC) sanctions programs, and Washington State money-transmission requirements.

1. Program governance

• A designated Compliance Officer is responsible for the AML program.
• The program is reviewed at least annually and updated as regulations evolve.
• Employees with customer-facing or compliance responsibilities receive periodic AML training.
• The program is subject to independent testing on a periodic basis.

2. Customer identification (CIP)

Before opening or activating an account, we collect and verify the following customer information, at minimum:

• Full legal name
• Date of birth
• Residential address
• Government-issued identification number (e.g. passport, driver's license)

We use third-party identity-verification providers and document checks to confirm the information provided. Customers who cannot be verified may be unable to use, or may have restricted access to, the Services.

3. Customer due diligence (CDD) and enhanced due diligence (EDD)

We collect additional information based on a customer's risk profile. Higher-risk relationships, including customers in higher-risk jurisdictions or with higher transaction volumes, are subject to enhanced due diligence, which may include source-of-funds documentation, additional identity checks, and periodic reviews.

4. Sanctions screening

We screen customers, beneficial owners, and counterparty wallet addresses against OFAC and other applicable sanctions lists at onboarding and on an ongoing basis. We do not provide Services to persons or entities, or transactions involving wallet addresses, that appear on these lists, and we do not operate in jurisdictions subject to comprehensive U.S. sanctions.

5. Transaction monitoring

We monitor transactions for unusual patterns or activity inconsistent with a customer's stated profile. Indicators include, but are not limited to:

• Structuring of transactions to avoid reporting thresholds
• Rapid movement of funds with no apparent economic purpose
• Transactions to or from high-risk addresses, mixers, or sanctioned jurisdictions
• Unusual activity inconsistent with a customer's KYC profile

We may delay, reject, or reverse instructions where permitted by law and may close accounts associated with prohibited activity.

6. Reporting and recordkeeping

• Suspicious Activity Reports (SARs): filed with FinCEN where required by 31 C.F.R. Chapter X.
• Currency Transaction Reports (CTRs): filed where applicable.
• Travel Rule: we collect and transmit required originator and beneficiary information for qualifying transmittals.
• Records: KYC, transaction, and compliance records are retained for at least five years from the relevant event, in line with BSA requirements.

7. Customer responsibilities

Customers are required to:

• Provide accurate and complete identification information
• Use the Services only for lawful purposes
• Promptly respond to compliance requests for additional information
• Notify us of any changes to identification, address, or ownership information

8. Confidentiality

U.S. federal law prohibits the disclosure of certain compliance reports, including SARs, to the subject of the report or any unauthorized third party.

9. Independent verification

Our regulatory standing can be independently verified through official U.S. regulator websites:

• FinCEN MSB Registrant Search — https://www.fincen.gov/msb-registrant-search (Registration No. 31000301673366)
• Washington State Department of Financial Institutions — https://dfi.wa.gov (Money Transmitter License No. 550-MT-159100)

10. Contact

To contact our compliance team, write to admin@zulallc.com or to the Compliance Officer, Zula LLC, 15035 Military Rd S, SeaTac, WA 98188, United States.