KYC & AML Policy
Sustainable Digital Assets (SDA)
Version 1.0Last updated: 18 August 2025
Summary: This policy explains how SDA identifies and verifies customers, applies AML/CTF controls, and implements the Crypto-Asset Transfer Rule. We operate a phased onboarding model: Phase 1 (presale utility-token access) and Phase 2 (regulated security-token/equity features).
Compliance: compliance@sdafintech.com
Time Stamped Document
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Key Points
- Below €1,000 cumulative: wallet and IP identification.
- €1,000 or higher: Full KYC is mandatory.
- Phase 2 access (security-token/equity features) requires Full KYC/KYB, refreshed screening, investor categorisation, and Travel-Rule-ready wallets.
- We apply risk-based EDD (PEPs, high-risk geographies, complex SoW).
- Travel Rule data exchanged on all external crypto transfers; self-hosted wallets > €1,000 require ownership proof.
Scope & Legal Basis
This policy covers onboarding, monitoring, and off-boarding of natural persons and legal entities interacting with SDA's token lifecycle. We follow applicable EU AML/CFT rules (including the Crypto-Asset Transfer Rule) alongside investor-protection duties where relevant. Local laws may impose additional requirements in certain jurisdictions.
Phase 1 — Presale / Utility-Token Access
Who: presale participants and holders during the utility-token phase.
We collect (everyone):
• Self-declaration: PEP status and sanctions screening.
• Wallet checks: proof of ownership (signed message or micro-tx loopback) for payout/withdrawal addresses.
Tiering during Phase 1:
- Tier A (under €1,000 cumulative, low risk):
– Wallet and IP identification only.
– Self-declaration PEP/sanctions status; geofencing for restricted countries.
- Tier B (≥ €1,000 or heightened risk):
– Photo ID capture + automated liveness/face-match or robust bank-KYC evidence (e.g., SEPA account in same name).
– Full KYC before further funding, voting, withdrawals or profit-sharing; apply EDD where flags exist.
We collect (everyone):
• Self-declaration: PEP status and sanctions screening.
• Wallet checks: proof of ownership (signed message or micro-tx loopback) for payout/withdrawal addresses.
Tiering during Phase 1:
- Tier A (under €1,000 cumulative, low risk):
– Wallet and IP identification only.
– Self-declaration PEP/sanctions status; geofencing for restricted countries.
- Tier B (≥ €1,000 or heightened risk):
– Photo ID capture + automated liveness/face-match or robust bank-KYC evidence (e.g., SEPA account in same name).
– Full KYC before further funding, voting, withdrawals or profit-sharing; apply EDD where flags exist.
What "Full KYC" Means (Standard)
Individuals
• Government ID (passport/ID card/driver's licence) + liveness/face-match; second document if needed.
• Proof of address (≤3 months): utility bill, bank/credit statement, government letter.
• Sanctions/PEP/adverse media cleared; PEPs require senior approval (EDD).
• Purpose & intended use; expected activity profile.
• Source of Funds (SoF) for the transaction; Source of Wealth (SoW) where size/risk warrants (e.g., payslips, tax returns, sale contracts, audited statements, exchange withdrawal histories).
• Ongoing monitoring and periodic refresh.
Entities (KYB)
• Legal name, registration number, registered address, formation documents/registry extract; LEI where available.
• Ownership & control: identify UBOs ≥25% or effective control; Full KYC on UBOs and directors/signatories.
• Business profile, licences (if applicable), expected activity.
• SoF/SoW at entity and UBO levels as appropriate.
• Sanctions/PEP/adverse media at entity/UBO/director levels; ongoing monitoring.
• Government ID (passport/ID card/driver's licence) + liveness/face-match; second document if needed.
• Proof of address (≤3 months): utility bill, bank/credit statement, government letter.
• Sanctions/PEP/adverse media cleared; PEPs require senior approval (EDD).
• Purpose & intended use; expected activity profile.
• Source of Funds (SoF) for the transaction; Source of Wealth (SoW) where size/risk warrants (e.g., payslips, tax returns, sale contracts, audited statements, exchange withdrawal histories).
• Ongoing monitoring and periodic refresh.
Entities (KYB)
• Legal name, registration number, registered address, formation documents/registry extract; LEI where available.
• Ownership & control: identify UBOs ≥25% or effective control; Full KYC on UBOs and directors/signatories.
• Business profile, licences (if applicable), expected activity.
• SoF/SoW at entity and UBO levels as appropriate.
• Sanctions/PEP/adverse media at entity/UBO/director levels; ongoing monitoring.
Phase 2 — Security-Token / Equity Features
Who: clients converting to, receiving, or transacting SDA's regulated security-token and any equity-linked rights.
Required before Phase 2 access:
• Full KYC/KYB completion and approval.
• Refreshed screening (sanctions/PEP/adverse media).
• Investor categorisation (retail vs. professional). If we give advice/portfolio-style features: record appropriateness/suitability questionnaires.
• SoF/SoW evidence aligned to transaction size/risk and distribution flows.
• Travel Rule readiness for any on/off-ramp crypto movements; self-hosted wallets > €1,000 require ownership proof.
Required before Phase 2 access:
• Full KYC/KYB completion and approval.
• Refreshed screening (sanctions/PEP/adverse media).
• Investor categorisation (retail vs. professional). If we give advice/portfolio-style features: record appropriateness/suitability questionnaires.
• SoF/SoW evidence aligned to transaction size/risk and distribution flows.
• Travel Rule readiness for any on/off-ramp crypto movements; self-hosted wallets > €1,000 require ownership proof.
Travel Rule (Crypto Transfers)
We collect and transmit required originator/beneficiary data for external crypto-asset transfers.
For CASP-to-CASP transfers, we exchange data using industry-standard messaging.
For self-hosted wallets, we apply ownership-proof procedures; above €1,000, we verify control (message-sign or loopback tx).
Transfers lacking minimum data or with unresolved red flags are rejected or held pending review.
For CASP-to-CASP transfers, we exchange data using industry-standard messaging.
For self-hosted wallets, we apply ownership-proof procedures; above €1,000, we verify control (message-sign or loopback tx).
Transfers lacking minimum data or with unresolved red flags are rejected or held pending review.
Risk-Based Approach & EDD
We score risk across customer, geography, product, delivery channel, and behaviour. EDD applies to: PEPs, high-risk jurisdictions/sectors, complex ownership, unusual velocity/structuring, or adverse media. EDD measures may include senior-management approval, stricter SoF/SoW, lower limits, or refusal/exit.
Acceptable Documents (Annex)
ID: passport; national ID; driver's licence (where accepted).
Address: bank/credit statement, utility bill, government letter, lease/tenancy (with authority contact), property tax.
SoF/SoW (examples): payslips, employment contract, audited statements, tax returns, company sale docs, inheritance/probate, exchange withdrawal history with bank trails.
Address: bank/credit statement, utility bill, government letter, lease/tenancy (with authority contact), property tax.
SoF/SoW (examples): payslips, employment contract, audited statements, tax returns, company sale docs, inheritance/probate, exchange withdrawal history with bank trails.
Data Protection & Retention
We store only data needed for AML/CTF, onboarding, servicing, and legal obligations.
KYC and transactional records are retained for the legally required period and then deleted or anonymised.
You may exercise privacy rights via privacy@sdafintech.com (subject to AML retention exemptions).
KYC and transactional records are retained for the legally required period and then deleted or anonymised.
You may exercise privacy rights via privacy@sdafintech.com (subject to AML retention exemptions).
Record-Keeping
We maintain reproducible records of who was identified, how, and when, including screening results, SoF/SoW evidence, investor categorisation (Phase 2), and Travel Rule data exchanges.
Moving from Phase 1 → Phase 2 (Client Checklist)
- ✅Completed Full KYC/KYB (ID + PoA + screening).
- ✅Provided SoF/SoW aligned to investment size.
- ✅Declared investor category; completed any required questionnaires.
- ✅Registered wallets with ownership proof (especially for self-hosted > €1,000).
- ✅Acknowledged policy & disclosures.
Sanctions & Restricted Territories
We do not onboard customers in sanctioned or prohibited jurisdictions. We may apply additional controls or decline service in high-risk locations or sectors consistent with our risk appetite and legal obligations.
Contact Compliance
Questions or escalations: compliance@sdafintech.com
Revision History
v1.0 — 18 Aug 2025: Initial publication; Phase 1/Phase 2 split; Travel Rule procedures; investor categorisation for Phase 2.