AML Compliance

Our Commitment

iCloser Ltd. is committed to preventing money laundering, terrorist financing, and other financial crimes. We maintain a comprehensive Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) program in compliance with applicable laws and regulations.

Regulatory Registration

Regulatory Framework

Our AML program complies with:

• Bank Secrecy Act (BSA)
• USA PATRIOT Act
• FinCEN Regulations for Money Services Businesses
• OFAC Sanctions Programs
• Financial Action Task Force (FATF) Recommendations

Know Your Customer (KYC)

We implement robust KYC procedures to verify the identity of our users:

Individual Customers

• Full legal name
• Date of birth
• Residential address
• Government-issued photo identification
• Proof of address
• Selfie verification (liveness check)

Business Customers

• Legal business name and structure
• Business registration documents
• Tax identification number
• Beneficial ownership information
• Authorized representatives and their identification

Customer Due Diligence (CDD)

We conduct risk-based due diligence on all customers:

• Standard Due Diligence: For low-risk customers with basic verification
• Enhanced Due Diligence (EDD): For high-risk customers, politically exposed persons (PEPs), or high-value transactions
• Ongoing Monitoring: Continuous review of customer activity and risk profiles

Transaction Monitoring

We employ automated systems to monitor transactions for suspicious activity:

• Real-time transaction screening
• Pattern analysis and anomaly detection
• Threshold-based alerts for large or unusual transactions
• Velocity checks and behavioral analytics
• Cross-border transaction monitoring

Sanctions Screening

All customers and transactions are screened against:

• OFAC Sanctions Lists (SDN, Consolidated Sanctions List)
• UN Security Council Sanctions
• EU Sanctions Lists
• Other International Sanctions Programs

Suspicious Activity Reporting (SAR)

We file Suspicious Activity Reports (SARs) with FinCEN when we detect:

• Transactions with no apparent lawful purpose
• Unusual patterns inconsistent with customer profile
• Attempts to evade reporting requirements (structuring)
• Potential money laundering or terrorist financing
• Fraud or identity theft indicators

Record Keeping

We maintain comprehensive records for at least 5 years, including:

• Customer identification and verification documents
• Transaction records and supporting documentation
• Account opening and closing records
• SAR and CTR filings

Training and Awareness

All employees receive regular AML/CTF training covering:

• Applicable laws and regulations
• Red flags and suspicious activity indicators
• Internal policies and procedures
• Reporting obligations and escalation procedures

Cooperation with Authorities

We cooperate fully with law enforcement and regulatory authorities, including:

• Responding to subpoenas and legal process
• Providing information for investigations
• Freezing accounts when legally required
• Participating in information-sharing initiatives

Contact Information

For AML compliance inquiries:

Email: compliance@icloser.xyz

Address: iCloser Ltd., 1580 N Logan St, Suite 660 #30327, Denver, CO 80203, USA