Identity verification/AML POLICY

1. INTRODUCTION
   This Policy outlines Delphi Delta Investment Corporation's ("Company") customer identification, verification, and anti-money laundering procedures for cryptocurrency trading services. As a U.S.-domiciled corporation under New York law, the Company complies with the Bank Secrecy Act (BSA), USA PATRIOT Act, FinCEN regulations (31 CFR Chapter X), SEC Regulation S-ID, and NY DFS BitLicense/AML Program requirements.

This Policy is integral to the Client Agreement. Clients must accept all terms before account activation. The Company may amend this Policy at any time with notice via platform/email.

1. LEGAL FRAMEWORK
   The Company maintains a comprehensive AML program per:
2. Bank Secrecy Act (BSA) as amended by USA PATRIOT Act
3. FinCEN Customer Identification Program (CIP) Rule (31 CFR § 1020.220)
4. FinCEN Travel Rule for crypto transfers (31 CFR § 1010.410(f))
5. SEC Regulation S-ID (17 CFR § 248.200 et seq.)
6. NY DFS Part 200 Transaction Monitoring & AML Program
7. OFAC sanctions programs

Core requirements include risk-based customer due diligence (CDD), ongoing transaction monitoring, suspicious activity reporting (SARs), and recordkeeping.

1. RISK-BASED APPROACH
   3.1 CLIENT VERIFICATION RISKS
   Enhanced Due Diligence (EDD) applied to:
2. High-risk jurisdictions (FATF grey/black lists)
3. PEPs and sanctions list matches
4. Complex corporate structures/obscured ownership
5. High-volume crypto transactions (> $10,000 daily)
6. Private wallet funding sources

Standard CDD for low-risk U.S. persons/institutions.

3.2 TIMING OF VERIFICATION

Full CIP completed prior to fund acceptance. Low-risk clients may deposit up to $2,500 pending verification (14-day completion required).

Non-compliant accounts frozen; unverified funds held in segregated account until Identity verification completion or returned to verified source.

1. CLIENT IDENTIFICATION REQUIREMENTS

4.1 NATURAL PERSONS

Required Information:

• Legal name, DOB, SSN/ITIN, U.S. address
• Phone, email, employment/occupation
• Source of funds/wealth declaration

Required Documents:

• Government-issued photo ID (passport/driver's license)
• Proof of address <90 days (utility bill/bank statement)
• Selfie with ID for facial recognition

4.2 LEGAL ENTITIES

Required:

• Certificate of Incorporation/Formation
• EIN/IRS confirmation
• Corporate resolution authorizing account
• Full UBO identification (>25% ownership threshold)
• Identity verification on all directors, officers, authorized signers
• Business purpose/source of funds documentation
• Latest financial statements (if revenue >$1M)

4.3 ENHANCED DUE DILIGENCE

PEP screening via World-Check/Sanctions lists. EDD includes:

• Source of wealth verification (tax returns, bank statements)
• Business legitimacy confirmation
• Transaction purpose documentation

1. ULTIMATE BENEFICIAL OWNER (UBO) VERIFICATION
   All entities must identify natural person UBOs (>25% ownership/control). Corporate chains traced to individual owners per FinCEN beneficial ownership rule (31 CFR § 1010.230).

1. POLITICALLY EXPOSED PERSONS (PEPs)
   Senior PEPs, family, close associates subject to mandatory EDD:
2. Enhanced source of funds scrutiny
3. Senior management approval required
4. Annual re-verification
5. Increased transaction monitoring thresholds

PEP definition per FinCEN guidance: foreign senior political figures, executives of international organizations.

1. HIGH-RISK TRANSACTIONS
   Mandatory review of:
2. Crypto deposits from unverified/private wallets
3. Round-trip transactions
4. Structuring attempts (<$10,000 multiples)
5. Mixing/tumbling service usage
6. Privacy coin transactions
7. Rapid in/out patterns inconsistent with profile

1. CONTINUOUS MONITORING
   Automated transaction monitoring system flags:
2. Velocity checks (transaction frequency/volume)
3. Geographic anomalies
4. Wallet clustering (Chainalysis integration)
5. Deviations from customer profile

Thresholds: SAR filing for >$5,000 suspicious activity.

1. RECORD KEEPING
   All Identity verification/AML records retained 5 years post-relationship per BSA (31 CFR § 1010.410). Includes:
2. Customer identification documents
3. Verification methods/results
4. Transaction records (on-chain + internal)
5. SAR/CTR filings
6. Risk assessments

1. UNACCEPTABLE JURISDICTIONS
   No services to OFAC-sanctioned jurisdictions or FATF high-risk jurisdictions including:
2. Crimea, Cuba, Iran, North Korea, Syria, Venezuela
3. FATF Black/Grey List countries
4. U.S. state-restricted venues

Full list published at delphidelta.com/restricted-jurisdictions.

1. REPORTING OBLIGATIONS
2. Currency Transaction Reports (CTRs) >$10,000 daily
3. Suspicious Activity Reports (SARs) via FinCEN BSA-E filing
4. Crypto Travel Rule compliance (VASP registration pending)
5. OFAC screening hits immediate freeze/report

1. CLIENT RESPONSIBILITIES
   Clients must:
2. Provide accurate/complete information
3. Update profile changes within 30 days
4. Not use VPNs/proxies to circumvent restrictions
5. Certify funds legitimate/non-sanctioned
6. Cooperate with additional verification requests

1. VIOLATIONS AND TERMINATION
   Breach of AML/Identity verification triggers:
2. Account freeze/termination
3. Fund blocking pending investigation
4. SAR filing to FinCEN
5. Law enforcement cooperation

No liability for legitimate fund blocking per regulatory requirements.

1. CONTACT
   AML Compliance Officer
   Delphi Delta Investment Corporation
   120 Wall Street, New York, NY 10005
   Email: aml@delphidelta.com

Effective: February 2026. Subject to regulatory updates.

© 2026 Delphi Delta Investment Corporation. All rights reserved.