AML / KYC

ALMOST A BANK, LLC maintains a written Anti-Money Laundering ("AML") program and Customer Identification Program ("CIP") designed to comply with the Bank Secrecy Act, FinCEN regulations, and Florida money services laws. This Policy summarizes our approach for Check2Crypto customers.

1. Program Governance

Our AML program includes designated compliance responsibility, periodic risk assessment, employee training, independent testing, and board or senior management oversight appropriate to our size and risk profile.

2. Customer Identification Program (CIP)

Before or at account opening, we collect and verify:

• Legal name, date of birth, and address for individuals
• Government-issued identification number and document images
• For businesses: legal name, EIN, address, formation documents, and beneficial owners holding 25% or more ownership or control

We use documentary and non-documentary methods, including third-party verification databases. Accounts may be restricted until CIP is complete.

3. KYC and KYB Procedures

Individual (KYC): Personal customers submitting personal checks must pass identity verification and ongoing due diligence scaled to transaction risk.

Business (KYB): Business customers submitting business checks must verify entity status, authorized signers, and beneficial ownership. We confirm the submitter's authority to act on behalf of the business.

Government checks: Enhanced verification may include agency validation, payee eligibility, and additional documentation for government-issued instruments.

4. Eligible Check Categories and Documentation

We accept personal, business, and government checks subject to enhanced review. Customers may be required to provide proof of account ownership, payee status, source of funds, invoices, contracts, or government correspondence supporting the transaction.

5. Sanctions Screening

Customers, beneficial owners, and related parties are screened against U.S. Treasury OFAC sanctions lists and other applicable restricted-party databases at onboarding and on an ongoing basis. We block or reject transactions involving sanctioned persons, countries, or regions as required by law.

6. AML and Fraud Screening

We screen customers and activity against law enforcement databases, adverse media, and internal fraud indicators. Check submissions are analyzed for alteration, forgery, duplicate presentment, and inconsistent payor/payee data.

7. Transaction Monitoring

Automated and manual monitoring reviews transaction patterns, velocity, structuring indicators, round-dollar anomalies, mismatched customer profiles, and high-risk jurisdictions. Alerts are investigated and escalated per internal procedures.

8. Source of Funds and Purpose

For higher-risk transactions, we may require documentation explaining the source of funds and commercial or personal purpose of the check. We may decline transactions we cannot reasonably justify under our risk tolerance.

9. Suspicious Activity Reporting

When we know, suspect, or have reason to suspect activity involves funds from illegal activity, is intended to evade BSA requirements, has no business or lawful purpose, or involves use of the Company to facilitate crime, we file Suspicious Activity Reports (SARs) with FinCEN as required. We do not disclose SAR filings to customers where prohibited by law.

10. Currency Transaction Reporting

We file Currency Transaction Reports and other reports when transactions meet applicable thresholds or regulatory requirements.

11. Recordkeeping

We maintain CIP records, transaction records, compliance decisions, and supporting documentation for at least five years from account closure or transaction date, or longer where required. Records are stored securely and accessible for regulatory examination.

12. Restricted Jurisdictions

We do not offer services to customers in jurisdictions where digital asset payouts or money services are prohibited, or where risk exceeds our appetite. Geographic restrictions may change without notice.

13. Prohibited Activity

Customers may not use Check2Crypto for activities listed in our Prohibited Use Policy. Violations may result in immediate termination and referral to authorities.

14. Ongoing Due Diligence

Customer risk ratings are reviewed periodically and upon trigger events (large transactions, returns, law enforcement inquiries, or negative news). We may request updated identification or enhanced documentation at any time.

15. Contact Compliance

Compliance inquiries: [email protected] · (719) 310-5065 · 879 Mason Ave, Daytona Beach, FL 32117

ALMOST A BANK, LLC is registered with FinCEN as a Money Services Business. FinCEN registration does not constitute approval, recommendation, endorsement, or verification by FinCEN.