KYC & AML Policy

1. Regulatory Framework

AssetsGrator operates under the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ("MLR 2017") and the Proceeds of Crime Act 2002 ("POCA"). All persons accessing investment functionality must complete identity verification before any on-chain interaction with asset tokens.

2. Who Must Complete KYC

All of the following must complete KYC before accessing the platform:

• Individual investors
• Corporate investors (additional beneficial ownership documentation required)
• Any wallet address that will hold, transfer, or receive Asset Tokens

There are no exemptions. The ERC-3643 smart contract will structurally block any transfer to a wallet not listed in the IdentityRegistry — KYC is enforced at the protocol level, not just administratively.

3. What We Verify

Individual investors:

• Government-issued photo ID (passport preferred)
• Proof of address (utility bill or bank statement, dated within 3 months)
• Investor classification declaration (high net worth / sophisticated investor)
• Source of funds / source of wealth (for investments above £10,000)
• PEP and sanctions screening

Corporate investors:

• Certificate of incorporation
• Memorandum and articles of association
• Register of directors and beneficial owners (persons with >25% ownership)
• KYC on each beneficial owner as per individual requirements
• Source of funds declaration

4. How On-Chain KYC Works

Upon successful KYC verification, two on-chain actions occur:

• T-REX Identity Claim: An on-chain identity claim is written to the IdentityRegistry contract, authorising the wallet to hold and transfer Asset Tokens under ERC-3643.
• Wallet Whitelisting: The wallet address is whitelisted in the compliance module — token transfers to non-whitelisted wallets are rejected at the smart contract level.

5. Investor Classification (UK)

To access the platform, investors must self-certify as one of the following under the Financial Promotions Order 2005:

• High Net Worth Individual: Net assets exceeding £250,000, or annual income exceeding £100,000
• Self-Certified Sophisticated Investor: Meets FCA criteria for experience and knowledge
• Professional Investor: FCA-defined professional client classification

Retail investors cannot access investment functionality under any circumstances.

6. PEPs and Sanctions

• Politically Exposed Persons (PEPs) are subject to Enhanced Due Diligence (EDD) before access is granted
• Wallets associated with sanctioned individuals or entities (OFAC / HM Treasury / UN / EU) are permanently blocked via the CountryRestrictModule
• Sanctions screening is re-run on all active investors on a weekly basis

7. Ongoing Monitoring

• KYC is re-verified every 12 months at minimum
• Material changes (change of name, nationality, beneficial ownership) must be notified immediately
• Continuous transaction monitoring is applied to on-chain activity
• Suspicious activity is reported to the National Crime Agency (NCA) via Suspicious Activity Report (SAR) where required

8. Data Handling

KYC data is handled in accordance with our Privacy Policy. Sensitive identity documents are stored securely off-chain, and only the verification status flag is recorded on the blockchain.