Compliance and Anti-Illegal Activity Policy (AML / CTF)
Hedger Investments LLC · Company No. 11402636 · 2756 Windjammer Rd, Suffolk, 23435-1456, Virginia, United States · Website: https://hedger.one · Email: [email protected]
1. General Provisions
1.1. This Anti-Money Laundering, Counter-Terrorist Financing, and Sanctions Compliance Policy (the "Policy") is adopted by Hedger Investments LLC (the "Company") for the purposes of preventing unlawful use of the Platform, minimizing regulatory and reputational risks, and ensuring sustainability of the Company's operations.
1.2. This Policy sets out principles, approaches, and procedures applied by the Company in AML/CTF risk management and applies to all Platform Users, employees, representatives, and contractors of the Company.
1.3. The Company operates in the field of Digital Assets and blockchain infrastructure and does not provide services for acceptance, custody, or transfer of fiat funds. At the same time, the Company follows internationally recognized AML/CTF principles and applies a risk-based approach to assessment of Users and their activity.
2. Definitions
For the purposes of this Policy, the following definitions apply.
2.1. AML (Anti-Money Laundering) means measures aimed at preventing legalization (laundering) of criminal proceeds.
2.2. CTF (Counter-Terrorist Financing) means measures aimed at preventing terrorist financing.
2.3. Platform means the website https://hedger.one and related digital interfaces, services, and functionality.
2.4. User means an individual registered on the Platform or interacting with its functionality.
2.5. Digital Assets means cryptographically secured digital units of value, including cryptocurrencies and other tokenized assets.
2.6. Suspicious Activity means actions or operations which, by nature, volume, frequency, or structure, may indicate attempts to launder proceeds, finance terrorism, evade sanctions, or otherwise engage in unlawful activity.
2.7. Sanctions Lists means lists of persons, organizations, and jurisdictions subject to international restrictive measures, including OFAC, EU, UK, and other applicable lists.
2.8. KYC (Know Your Customer) means User identification and verification procedures.
2.9. Risk-Based Approach means a method of risk assessment and management whereby the scope and depth of verification measures depend on the identified level of risk.
3. Principles and Regulatory Basis
3.1. The Company adheres to principles of legality, good faith, proportionality, and reasonable diligence in implementing this Policy.
3.2. This Policy takes into account generally accepted international AML/CTF standards and principles reflected in FATF recommendations and other international guidance applicable to Digital Asset activities.
3.3. The Company does not position itself as a traditional banking or financial institution; however, it seeks to maintain an appropriate level of compliance control consistent with the nature of its activities.
4. Responsibility and Governance
4.1. The Company appoints a responsible person or department authorized to monitor compliance with this Policy (the "Compliance Officer").
4.2. The Compliance Officer is responsible for: AML/CTF risk assessment; analysis of suspicious activity; decisions on restrictive measures; interaction with competent authorities within limits established by applicable law.
4.3. Company personnel must comply with this Policy and assist in identifying potential violations.
5. Risk Assessment and Management
5.1. The Company applies a risk-based approach when assessing Users and their activity.
5.2. Risk assessment may take into account: User jurisdiction; nature and volume of operations; frequency and structure of transactions; interaction with high-risk addresses; use of anonymization tools; inconsistency between actual behavior and declared activity model.
5.3. Depending on the risk level, the Company may apply additional control measures, including document requests and temporary functionality restrictions.
6. User Identification and Verification
6.1. As of the publication date of this Policy, mandatory identity verification is not automatically applied to all Users.
6.2. The Company reserves the right to implement KYC procedures and Digital Asset source-of-funds checks at any time in the event of: changes in applicable law; requirements of partners or infrastructure providers; achievement of certain User activity thresholds; identification of elevated risk.
6.3. The Company may request identity documents, proof of residence, information on the source of Digital Assets, and other information.
6.4. Refusal to undergo verification or provision of inaccurate information may result in restricted access to the Platform, suspension of operations, or termination of Account servicing.
7. Activity Monitoring
7.1. The Company may monitor User activity to detect suspicious operations.
7.2. Analysis may involve automated systems, blockchain analytics tools, and other technical means.
7.3. The Company may temporarily suspend operations, accrual or distribution of bonuses, and access to functionality for the period of an internal review.
8. Prohibited Use
The Platform is not intended for use for purposes of: money laundering; terrorist financing; evasion of international sanctions; fraud; market manipulation or other unlawful conduct.
The Company may restrict or terminate access to the Platform upon detection of such conduct.
9. Sanctions Compliance
9.1. The Company does not service persons subject to international sanctions.
9.2. The Platform may be unavailable to Users from high-risk jurisdictions, including, without limitation: the United States, Iran, North Korea, Cuba, Syria, and other territories subject to international restrictions.
9.3. The Company may apply geographic restrictions and other access-control measures without providing reasons.
10. Data Retention and Protection
10.1. Information obtained in implementation of this Policy may be retained for the period necessary to comply with legal requirements and internal risk-management procedures.
10.2. The Company applies reasonable technical and organizational measures to protect data from unauthorized access.
11. Interaction with Competent Authorities
11.1. The Company may provide information to competent public authorities upon lawful request and within the limits established by applicable law.
12. Policy Amendments
12.1. The Company may amend this Policy at any time.
12.2. The current version of this Policy is published on the Website. Users are advised to review updates regularly.