KYC / AML Policy

Sebastian Alliance Group LLC ("SAG") is committed to preventing the use of its platforms and services for money laundering, terrorist financing, sanctions evasion or any other financial crime. This Know-Your-Customer / Anti-Money-Laundering ("KYC/AML") Policy summarises the controls SAG applies to onboarding, monitoring and reporting.

SAG operates from the United States and observes applicable requirements under: the Bank Secrecy Act (BSA), USA PATRIOT Act, rules published by the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC), Florida state law, and card-network rules (Visa, Mastercard, American Express, Discover). Where SAG facilitates payments in other jurisdictions, we cooperate with the local regulated processor or banking partner responsible for compliance in that jurisdiction.

SAG is not itself a bank, money services business or money transmitter. Payment settlement is performed by regulated third-party processors (including Stripe, Inc. and Fiserv, Inc.), each of which applies its own KYC/AML programme.

Before a merchant, corporate client or high-value payer is onboarded, SAG collects and verifies identifying information appropriate to the risk of the relationship. This typically includes:

For individuals:

• Full legal name, date of birth, residential address.
• Government-issued photo ID (passport, driver's licence or national ID).
• Proof of address dated within the last 90 days (utility bill, bank statement).
• Tax identification number where applicable (SSN, ITIN or foreign equivalent).

For entities:

• Certificate of incorporation, articles of organisation or equivalent.
• Certificate of good standing (dated within the last 6 months).
• Registered business address and operating address.
• EIN or foreign tax identification number.
• Ownership structure and identification of beneficial owners holding 25% or more, and one control person, in line with FinCEN's beneficial-ownership rule.
• Business licence(s) where required by the jurisdiction of operation.

All customers, beneficial owners and control persons are screened against consolidated sanctions lists — including but not limited to OFAC SDN, EU consolidated sanctions, UK OFSI, and UN Security Council lists — and against politically-exposed-person (PEP) and adverse-media data at onboarding and on an ongoing basis. A confirmed match will result in refusal or termination of the relationship and, where required by law, a report to the appropriate authority.

SAG assigns each customer a risk rating (low, medium, high) based on factors including: type of business, geography, expected transaction volume and pattern, involvement of high-risk jurisdictions, use of cash-intensive activity, and the presence of PEPs. Higher-risk relationships receive enhanced due diligence (EDD), including source-of-funds evidence, senior approval and more frequent review.

SAG platforms may not be used to sell or accept payment for, among other things: illegal narcotics; unlicensed pharmaceuticals; weapons, ammunition or explosives; child sexual abuse material or any other illegal content; human trafficking or forced labour; unlicensed gambling or lotteries; unregistered securities offerings or investment schemes; multi-level-marketing pyramid schemes; shell-company facilitation; goods or services sanctioned by the United States or an applicable jurisdiction; and any activity contrary to card-network rules or applicable law.

Transactions processed on SAG platforms are monitored for patterns consistent with money laundering, terrorist financing, fraud or sanctions evasion — including structuring, rapid movement of funds, unusual chargeback rates, and mismatches between declared business type and actual activity. Alerts are reviewed by compliance personnel and escalated where necessary.

SAG cooperates with regulated processors and banking partners in the filing of Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) where triggered. Where SAG has a direct obligation to report, it does so in accordance with US federal and Florida state law. Customers are prohibited from "tipping off" any person that a report has been or may be filed.

KYC files, transaction records, screening results, alert investigations and any reports made are retained for at least five (5) years after the end of the relationship or the date of the transaction, whichever is later, unless a longer period is required by law.

SAG maintains a written AML programme approved by senior management, designates a compliance officer responsible for its day-to-day operation, delivers periodic training to staff who onboard customers or handle transactions, and engages independent testing of the programme on a risk-appropriate cadence.

SAG reserves the right to refuse an application, restrict functionality, hold or reverse funds, and terminate any account where a KYC/AML, sanctions, fraud or acceptable-use concern arises, in line with our Terms of Service and applicable law.

To report a concern, request a copy of the information we hold about you, or contact the SAG compliance function, email ecommerce@sebasalliance.net.