AML Compliance

AML Compliance with Chainalysis Address Screening

Introduction

At Gray Digital, we are committed to upholding the highest standards of Anti-Money Laundering (AML) compliance. As part of our compliance efforts, we have implemented Chainalysis Address Screening, an industry-leading blockchain intelligence solution. This document outlines the features and benefits of Chainalysis Address Screening and how it helps us ensure a secure and compliant environment for our users.

1. Purpose

The purpose of implementing Chainalysis Address Screening is to prevent high-risk users from connecting to our platform. By evaluating the source of funds and conducting comprehensive risk assessments, we aim to build trust with our customers and demonstrate our proactive development of compliance controls.

2. Compliance Obligations

2.1 Use of Chainalysis Address Screening

The User acknowledges and agrees to the use of Chainalysis Address Screening, an industry-leading blockchain intelligence solution, for AML compliance purposes. The User understands that their blockchain addresses and transactions will be screened against risk indicators and compliance rules to identify and prevent high-risk activities.

2.2 Source of Funds Verification

The User agrees to provide accurate and complete information regarding the origin and legitimacy of funds associated with their blockchain addresses. The Company reserves the right to conduct additional due diligence and verification procedures to ensure compliance with applicable AML regulations.

2.3 Compliance with Applicable Laws

The User agrees to comply with all applicable local, national, and international AML laws, regulations, and guidelines. The User shall not engage in any activities that may facilitate money laundering, terrorist financing, or other illicit activities.

2.4 Reporting of Suspicious Activity

The User understands and acknowledges their obligation to report any suspicious activity or transactions to the Company promptly. The User shall provide all necessary information and cooperate fully with the Company in investigating and reporting such activities as required by law.

2.5 Compliance Training

The User agrees to undergo AML compliance training provided by the Company or its designated representatives. The User acknowledges the importance of understanding and adhering to AML policies and procedures.

3. Confidentiality and Data Security

3.1 Data Protection

The Company will handle and protect all personal data and information collected during the AML compliance process in accordance with applicable data protection laws and regulations. The User's data will only be used for AML compliance purposes and will not be disclosed to any unauthorized third parties without the User's consent, except as required by law.

3.2 Security Measures

The Company has implemented appropriate technical and organizational measures to safeguard the integrity and confidentiality of the User's data. However, the User acknowledges that no data transmission or storage can be guaranteed to be 100% secure, and the Company shall not be held liable for any unauthorized access or data breaches that may occur.

4. Termination

4.1 Termination for Non-Compliance

The Company reserves the right to suspend or terminate the User's access to the Gray Digital platform in the event of non-compliance with AML policies and procedures or any suspicious or illegal activities. The Company may also report such activities to the relevant authorities as required by law.

4.2 Termination by User

The User may terminate this Agreement by providing written notice to the Company. However, the User understands that termination does not relieve them of their responsibility to comply with applicable AML laws and regulations.

5. Governing Law and Jurisdiction

This Agreement shall be governed by and construed in accordance with the laws of the State of Delaware. Any disputes arising out of or in connection with this Agreement shall be subject to the exclusive jurisdiction of the courts of the State of Delaware.

6. Entire Agreement

This Agreement constitutes the entire understanding between the Company and the User regarding AML compliance and supersedes any prior agreements or understandings, whether written or oral, relating to the subject matter hereof.

By accessing or using the Gray Digital platform, the User acknowledges that they have read, understood, and agreed to comply with this AML Compliance Agreement.