Compliance

AML / KYC Policy

Last updated: January 1, 2026

Spring Light LLC operates a written Anti-Money Laundering ("AML") program designed to comply with the U.S. Bank Secrecy Act ("BSA"), implementing FinCEN regulations, applicable U.S. state money transmitter laws, and economic sanctions administered by the U.S. Office of Foreign Assets Control ("OFAC"). This page summarises key elements of that program.

1. Program governance

• A designated AML / BSA Compliance Officer is responsible for day-to-day administration of the program.
• The program is reviewed and approved by senior management.
• The program is subject to periodic independent testing.
• Personnel receive training appropriate to their role on AML, sanctions and customer due diligence requirements.

2. Customer Identification & Due Diligence (KYC / CDD)

Before allowing a customer to transact, Spring Light verifies the customer's identity in line with applicable Customer Identification Program (CIP) requirements. KYC information collected includes:

• Full legal name
• Date of birth
• Residential address and country of residence
• Government-issued identification document and supporting biometric/liveness verification

Customers are screened against applicable sanctions lists (including OFAC) at onboarding and on an ongoing basis. We apply Enhanced Due Diligence ("EDD") to higher-risk customers and transactions, including requests for source-of-funds information.

3. Transaction monitoring

• All transactions are subject to risk-based monitoring designed to detect suspicious or unusual activity.
• We use blockchain analytics to assess the risk of inbound and outbound transfers, including exposure to sanctioned addresses, darknet markets, mixers and other high-risk counterparties.
• Transactions may be paused, declined or reversed where required for compliance review.

4. Recordkeeping & reporting

• We maintain customer identification, transaction and monitoring records for at least the periods required by law (typically five years).
• We file Suspicious Activity Reports ("SARs") and any other required reports with FinCEN.
• We respond to lawful requests from regulators and law enforcement.
• We comply with applicable Travel Rule requirements for qualifying transfers.

5. Sanctions

Spring Light maintains a sanctions compliance program designed to prevent prohibited dealings with sanctioned persons or jurisdictions. We screen customers and counterparty addresses, and we block or reject transactions as required by U.S. sanctions law. See our restricted jurisdictions list.

6. Customer obligations

By using Spring Light, you agree to provide accurate identity, residency and source-of-funds information, to update that information when it changes, and not to use the Services to facilitate any illegal activity. Misrepresentation may result in immediate account closure and reporting to the relevant authorities.

7. Confidentiality of compliance actions

Federal law restricts our ability to discuss specific compliance actions, including any decision to file a Suspicious Activity Report. We will not confirm or deny the existence of any particular SAR or investigation.

8. Contact

To contact our compliance team — for example, regarding a regulatory request, court order or compliance question — email admin@springlightllc.com with the subject line "Compliance inquiry".