Anti-Money Laundering Policy

Last updated: March 2026

1. Purpose and Scope

This Anti-Money Laundering ("AML") Policy outlines the procedures and controls Trust Wallet Card maintains to detect, prevent, and report money laundering, terrorist financing, and other financial crimes. This policy applies to all users of our Services and all employees, contractors, and partners involved in the provision of our card services.

2. Regulatory Framework

Trust Wallet Card operates in compliance with applicable AML laws and regulations in all jurisdictions where our Services are offered, including but not limited to:

• Financial Action Task Force (FATF) Recommendations
• EU Anti-Money Laundering Directives (AMLD)
• US Bank Secrecy Act (BSA) and FinCEN regulations
• UK Money Laundering Regulations
• Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act

3. Risk-Based Approach

We employ a risk-based approach to AML compliance. This includes assessing risks associated with customers, products, services, delivery channels, and geographic regions. Higher-risk scenarios are subject to enhanced due diligence measures.

4. Customer Due Diligence

4.1 Wallet Verification

All users must connect a verified non-custodial wallet. We utilize blockchain analytics to assess the risk profile of connected wallet addresses, including transaction history and associations with known illicit addresses.

4.2 Enhanced Due Diligence

For high-value transactions or accounts flagged by our monitoring systems, we may request additional verification including proof of source of funds and documentation of the legitimate origin of cryptocurrency holdings.

5. Transaction Monitoring

We maintain automated systems that continuously monitor all transactions for suspicious activity. Our monitoring covers:

• Unusual transaction patterns or volumes
• Transactions involving high-risk jurisdictions
• Structuring or attempts to circumvent reporting thresholds
• Interactions with addresses flagged on sanctions lists or associated with criminal activity
• Rapid movement of funds inconsistent with the user's profile

6. Sanctions Compliance

Trust Wallet Card screens all users and transactions against applicable sanctions lists, including those maintained by OFAC (US), the European Union, the United Nations, and HM Treasury (UK). Card services are not available in sanctioned jurisdictions or to sanctioned individuals and entities.

7. Suspicious Activity Reporting

Where we identify or have reasonable grounds to suspect money laundering or terrorist financing, we will file Suspicious Activity Reports (SARs) with the relevant Financial Intelligence Unit (FIU) in accordance with applicable law. We are prohibited from disclosing to users that a report has been filed.

8. Record Keeping

We maintain comprehensive records of all customer identification documents, transaction records, and AML-related reports for a minimum of 5 years (or longer where required by local regulations) from the date the relationship ends or the transaction is completed.

9. Training

All relevant personnel receive regular AML training covering current regulations, red flags for suspicious activity, and internal reporting procedures. Training records are maintained and reviewed annually.

10. Compliance Officer

Our designated AML Compliance Officer is responsible for overseeing the implementation and effectiveness of this policy. For AML-related inquiries, contact [email protected].

11. Policy Review

This policy is reviewed and updated at least annually, or more frequently in response to changes in regulations, emerging risks, or significant events. All updates are approved by senior management.