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STANDARD OPERATIONS PROCEDURE

Know Your Customer

Introduction

Aegis.im (“Aegis”, “Project”, “we,” “our,” or “us”) is committed to operate with the highest standards of integrity, transparency, and responsibility. This Anti-Money Laundering (AML) Policy (“Policy”), outlines our commitment to prevent, detect, and report money laundering activities and other financial crimes. This Standard operation procedure (“SOP”) set up rules for implementing AML requirements.

Scope: This policy applies to all employees, board members, contractors, and associated parties of the foundation.

Important Note: This SOP is based on the Code of Business Conduct (“CoBC”) of Aegis and is a part of AML Policy. In case of any provisions of the SOP contradict provisions of AML Policy or CoBC, it will prevail in relation with Customers. Aegis commits to bring the SOP in line with AML policy and CoBC within a business week after non-compliance was highlighted.

1. Definitions

The following terms with accordant definitions are used in the present SOP:

  • Aegis Protocol: Refers to Aegis DAO developed and maintained The decentralized blockchain infrastructure to provide secure, efficient, and transparent financial solutions for AEG tokenholders.
  • Aegis DAO: The decentralized autonomous organization (DAO) that governs the Aegis ecosystem. Aegis DAO manages decisions related to the Aegis.im protocol, treasury, and ecosystem growth.
  • Customer: Means:
    • A member of Aegis DAO
    • A tokenholder
    • Any legal or natural person who requires any services from DAO or Aegis or uses its infrastructure
  • Foundation: Refers to the Aegis DAO Foundation, a Cayman Islands foundation company established to facilitate operations, including (but not limited to) managing connections with Web2 service providers, custodians, exchanges, and other third-party entities to support the decentralized ecosystem.

2. Customers’ Classification and General Procedure

2.1 Types of Customer Due Diligence

There are three main types of customer due diligence:

  1. High-level: For users with limited and standardized interactions
  2. General: For users that sends funds into our protocol like DAO members, token holders
  3. Enhanced: For high-risk customers, including:
    • Politically Exposed Persons (PEPs)
    • Customers from high-risk jurisdictions
    • Customers with complex ownership structures

2.2 High-level KYC Check Includes:

  • Verifying crypto-wallet address and transactions associated with it
  • Identifying country of residence
  • Funds clearance due diligence
  • Conducting ongoing due diligence on existing matters

2.3 General KYC Procedure

Applicable for all users connecting crypto-wallet to Aegis’ protocol:

  • Verifying crypto-wallet address and transactions associated with it
  • Identifying country of residence
  • Funds clearance due diligence
  • Verifying customer identity using reliable, independent source documents
  • Identifying beneficial owners of legal entities
  • Understanding the nature and purpose of customer funds
  • Conducting ongoing due diligence

2.4 Enhanced KYC Procedure

Includes all of the following:

  • Verifying crypto-wallet address and transactions
  • Identifying country of residence
  • Funds clearance due diligence
  • Verifying customer identity using reliable documents
  • Identifying beneficial owners, main exec persons and entities
  • Understanding nature and purpose of customer funds
  • Identifying and monitoring of affiliates
  • Conducting ongoing due diligence

2.5 KYC Results

Customers can be either approved or rejected. If approved, they are classified for the accordance level of interaction with certain functionality.

2.6 Review Periods

KYC results are reviewed on a regular basis:

  • 3 years for high-level customers
  • 2 years for general customers
  • 1 year for high-risk customers

2.7 Alert Handling

If there are alerts during ongoing due diligence, customer’s activity should be suspended until the end of the alert investigation.

3. Checkpoints

3.1 Initial Registration Process

When a legal or natural person intends to interact with Aegis ecosystem:

  1. Customer initiates interaction
  2. Automated processing and classification
  3. Data collection (10 business day deadline)
  4. Application review with following timeframes:
    • Up to 24 hours for high-level assessment
    • Up to 3 business days for general assessment
    • Up to 10 business days for enhanced assessment
  5. Terms can be extended with notification

3.2 Reassessment Triggers

Reassessment can be initiated by:

  • Regular re-assessment schedule
  • Red-flags and alerts during monitoring
  • Whistleblowing system information
  • Unusual or suspicious transactions
  • Customer re-classification
  • Audit findings

4. Tiered Verification System

Tier 1 (High-level)

  • Wallet address
  • Assets clearance

Tier 2 (General)

  • Government-issued ID upload
  • Proof of address
  • Selfie with ID and handwritten note
  • Phone number verification
  • E-mail

Tier 3 (Enhanced)

All Tier 2 requirements plus:

  • Enhanced due diligence for high-risk countries
  • Source of funds declaration

5. Document Verification

  • AI-powered document verification software is used
  • Human review of all cases
  • Compliance officer team reviews flagged cases

6. Risk Assessment

6.1 Risk Score Components:

  • Country of residence
  • Transaction patterns
  • Source of funds
  • Funds clearance
  • Customer correspondents
  • PEP status

7. Ongoing Monitoring

  • Continuous on-chain and off-chain monitoring
  • Transaction monitoring for suspicious activities
  • 8-hour alert processing timeline
  • Activity freeze during reviews
  • 5-business-day off-boarding process when necessary

8. Data Privacy

  • Compliant data storage
  • Localization requirements
  • Organizational and technical protections
  • Strict access controls
  • Government data sharing notifications

9. Compliance Reporting

We generate reports for internal audits and regulatory compliance and maintain detailed logs of all KYC processes and decisions.

10. User Support

Clear instructions and support are provided for all Customers during the KYC process.

11. Third-Party Partnerships

  • Engagement with reputable KYC/AML service providers
  • Due diligence of third-party solutions
  • Regular audits and assessments
  • Transparency in solution ownership

Last updated: [Current Date]

For questions about this policy, please contact our compliance team.