Arc-Fi AML and KYC Policy
1. Commitment
1.1 Arc-Fi is committed to preventing money laundering, terrorist financing and sanctions evasion through its platform.
1.3 This policy applies to every account holder, every affiliate paid a commission, and every member of staff with access to customer funds.
1.4 This policy is reviewed annually and following any material change to products, jurisdictions or payment methods.
2. Customer identification
2.1 Arc-Fi does not permit anonymous accounts. Identity verification is required before a first withdrawal and before any deposit above the Tier 1 threshold.
Tier
Cumulative deposits
Information required
1
Email, phone, full legal name, date of birth, country of residence
2
Government-issued photo identification, liveness check, residential address
3
Tier 2, plus proof of address dated within three months and evidence of source of funds
2.2 Enhanced due diligence applies to politically exposed persons and their associates, customers in higher-risk jurisdictions, deposits originating from mixing services or privacy coins, and accounts whose activity is inconsistent with the stated customer profile.
2.3 Affiliates are verified to Tier 2 before their first payout, with tax documentation on file.
2.4 Accounts that fail verification are closed and funds returned to their source of origin.
3. Sanctions screening
3.1 All account holders and affiliates are screened at onboarding and rescreened regularly against applicable sanctions lists, including OFAC, UN, UK and EU lists.
3.2 Arc-Fi does not onboard, and will freeze, any person appearing on a sanctions list or resident in a comprehensively sanctioned territory.
3.3 Incoming deposits are screened using blockchain analytics. Funds traced to sanctioned entities, darknet markets, ransomware or known thefts are frozen pending review.
4. Ongoing monitoring
4.1 Arc-Fi monitors account activity for indicators including deposits withdrawn quickly without trading, multiple accounts sharing devices or payment sources, deposits structured below verification thresholds, reluctance to verify, altered documents, and requests to withdraw to third-party wallets.
4.2 Where a member’s declared country and access location repeatedly differ, the account is reviewed.
5. Escalation and reporting
5.1 Staff escalate concerns to the MLRO the same day, in writing.
5.3 Where required by law, the MLRO files a report with the relevant authority within the statutory deadline.
5.4 Staff must not disclose to a customer that their activity has been escalated or reported.
6. Records and training
6.2 Staff in customer-facing and payment roles complete AML training at onboarding and annually.
6.3 Affiliates receive training covering red flags and the rule that they must never accept funds, credentials or wallet access from a prospect.