Anti-Money Laundering (AML) Policy

1 Purpose

iEvolution Pro LLC, Nuvix, and all affiliated companies are committed to preventing money laundering and terrorist financing. This Anti-Money Laundering (AML) Policy is established to ensure compliance with:

• The Bank Secrecy Act (BSA)
• The USA PATRIOT Act
• Financial Action Task Force (FATF) recommendations
• Office of Foreign Assets Control (OFAC) sanctions
• International AML regulations applicable in all authorized operating countries

2 Scope

This policy applies to:

• All employees of iEvolution Pro LLC, Nuvix, and affiliated companies
• Independent Brand Partners (IBPs)
• Contractors and consultants
• Business partners and affiliates
• Third-party service providers
• Any person or entity conducting business with or on behalf of our companies

3 Definition and Processing

Money laundering is the process of making illegally-gained proceeds appear legal by disguising the true origin of funds. It typically involves three stages:

4 Compliance Program

4.1 AML Compliance Officer

iEvolution Pro LLC designates an AML Compliance Officer responsible for:

• Implementing and overseeing AML policies and procedures
• Monitoring transactions and reporting suspicious activities
• Training employees and IBPs on AML compliance
• Ensuring compliance with national and international AML laws
• Conducting regular risk assessments
• Maintaining relationships with regulatory authorities

4.2 Know Your Customer (KYC) Procedures

To prevent money laundering, we will verify the identity of all customers, IBPs, and business partners through:

4.2.1 KYC Control Provider and Technology Infrastructure

Our KYC control technology includes:

• Real-time identity verification against government databases
• Automated sanctions screening against OFAC SDN, UN, EU, and UK sanctions lists
• Tax ID validation and masking for SSN/EIN (USA) and tax IDs across 150+ countries
• Multi-document verification support
• Risk-based conditional approval workflows
• Blockchain address screening for cryptocurrency transactions
• Complete audit trail and compliance reporting

Enhanced Due Diligence Partners: For high-risk transactions or when required by local regulations, we integrate with leading third-party KYC providers including:

• Sumsub - For biometric verification and enhanced document authentication
• ComplyAdvantage - For real-time sanctions and PEP screening
• LexisNexis Risk Solutions - For comprehensive background checks

4.3 Transaction Monitoring

We monitor all transactions to identify red flags, including:

4.4 Record Keeping

All customer and transaction records will be retained for a minimum of five (5) years, including:

• Customer identification documents
• Transaction records and payment history
• Internal reviews and suspicious activity reports
• Communication records related to high-risk transactions
• Training records and compliance certifications

4.5 Suspicious Activity Reporting (SAR)

Employees and IBPs must immediately report any suspicious transaction to the AML Compliance Officer, who will determine whether to file a Suspicious Activity Report (SAR) with appropriate regulatory authorities.

4.6 Training and Awareness

All employees and IBPs will receive comprehensive AML compliance training, including:

• AML laws and regulatory obligations
• Identification of suspicious activities and red flags
• Internal reporting procedures
• Customer due diligence requirements
• Consequences of non-compliance
• Annual refresher training and updates on regulatory changes

5 Prohibited Transactions

Sanctions Screening

All customers and transactions are screened against:

• OFAC Specially Designated Nationals (SDN) List
• UN Security Council Sanctions List
• EU Consolidated Sanctions List
• HM Treasury Sanctions List (UK)
• Local sanctions lists in operating jurisdictions

6 Enforcement and Sanctions

Non-compliance with this AML policy may result in severe consequences:

Legal Consequences

Violations of AML laws can result in:

• Criminal prosecution and imprisonment
• Substantial monetary fines (up to millions of dollars)
• Asset forfeiture
• Reputational damage
• Loss of professional licenses

7 Review and Updates

This AML policy will be:

• Reviewed annually by the AML Compliance Officer and senior management
• Updated as necessary to reflect changes in regulations and business operations
• Assessed for effectiveness through regular audits
• Modified based on emerging risks and regulatory guidance

8 Data Retention Policy

In accordance with regulatory requirements, iEvolution Pro LLC and Nuvix maintain the following data retention standards:

• Customer identification records: 5 years after account closure
• Transaction records: 5 years from transaction date
• Suspicious Activity Reports: 5 years from filing date
• Training records: 5 years from training completion
• Risk assessments: 5 years from assessment date
• Correspondence with regulators: Permanently retained

Contact Information

For questions or to report suspicious activities, contact: