AML & CFT Policy

1.1. Meveridge ("Meveridge," "Platform," "we," or "us") is committed to preventing the use of its financial services and digital ecosystem for the purposes of money laundering, terrorist financing, fraud, and other illicit financial activities.

1.2. This Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Policy (the "Policy") is designed to establish a comprehensive framework of controls, checks, and balances to ensure strict compliance with international regulatory standards and to protect the integrity of the Platform.

1.3. Meveridge management and all personnel strictly adhere to a "Zero Tolerance" approach regarding financial crime. Any User found in violation of this Policy will face immediate Account termination, forfeiture of funds pursuant to applicable law, and reporting to the relevant authorities.

2.1. While maintaining a global operational footprint, Meveridge designs its AML/CFT framework in alignment with the recommendations and guidelines established by the Financial Action Task Force (FATF).

2.2. Our compliance program incorporates the core pillars of an effective AML framework:

• A system of internal policies, procedures, and controls.
• Designation of a qualified Chief Compliance Officer (CCO).
• Ongoing internal and independent audit functions to test the program.
• Continuous training programs for platform personnel.
• Implementation of risk-based Customer Due Diligence (CDD) procedures.

2.3. Users must acknowledge that Meveridge operates in a dynamic regulatory environment concerning virtual assets and stablecoins (e.g., USDT). We reserve the right to amend this Policy without prior notice to comply with emerging legal directives.

Meveridge implements a risk-based, tiered approach to "Know Your Customer" (KYC) verification, ensuring that onboarding friction is balanced against the financial risk posed by higher transaction volumes.

3.1 Tier 1: Basic Verification

• Purpose: Initial onboarding and low-volume entry.
• Requirements:

- Verified Email Address.

- Verified Mobile Phone Number via SMS OTP.

- Completion of basic profile information (Full Name, Date of Birth, Nationality).

• Restrictions: Deposits are strictly limited to $5,000 per month.

3.2 Tier 2: Identity Verification

• Purpose: Standard investor profile and normal platform operations.
• Requirements:

- Submission of a valid, government-issued photo identification document (Passport, National ID Card, or Driver's License).

- Successful completion of a biometric "Liveness Check" (Live Selfie) to verify that the person matches the submitted document and is physically present.

• Restrictions: Deposits are limited to $50,000 per month.

3.3 Tier 3: Enhanced Due Diligence (EDD)

• Purpose: High-net-worth individuals and institutional clients.
• Requirements:

- Valid Proof of Address (e.g., utility bill, bank account statement, or municipal tax document) dated within the last three (3) months.

- Valid Source of Funds (SoF) documentation proving the legitimate origin of the capital (e.g., tax returns, payslips, dividend statements, or business ownership documents).

• Restrictions: Unlimited deposit capabilities.

4.1. Beyond the Tier 3 requirements, Meveridge may, at its sole discretion, mandate EDD procedures for any User, regardless of transaction volume, if a high-risk scenario is identified.

4.2. High-risk scenarios triggering EDD include, but are not limited to:

• Users residing in or operating from jurisdictions categorized as elevated risk (but not fully prohibited).
• Users flagged as Politically Exposed Persons (PEPs) or closely associated with PEPs.
• Accounts exhibiting complex, unusually large, or anomalous transaction patterns identified by AI GUARD.
• Accounts where an ownership discrepancy is suspected.

4.3. In EDD cases, the compliance team may request notarized documents, in-depth interviews via secure video link, and detailed questionnaires regarding wealth generation.

5.1. Initial CDD is not a one-time event. Meveridge conducts ongoing monitoring of the business relationship and scrutinizes transactions continuously.

5.2. AI GUARD System:We deploy a proprietary artificial intelligence behavioral analysis engine, "AI GUARD," to monitor 100% of deposit, withdrawal, and internal platform activities in real-time.

5.3. AI GUARD's ongoing monitoring capabilities include:

• Cross-referencing transaction volumes against the User's declared income profile and KYC Tier.
• Tracking wallet addresses involved in incoming deposits against global databases of compromised or sanctioned addresses.
• Monitoring login IPs relative to the stated country of residence and tracking suspicious geolocation jumps.
• Real-time assessment of the User's Security Score to correlate technical vulnerabilities with financial behavior.

6.1. The compliance team, aided by AI GUARD, actively screens for established AML/CFT "Red Flags". Detection of these typologies may result in the immediate freezing of the User's Available Balance and Invest Balance.

6.2. Key Red Flags monitored on the Platform:

• Structuring (Smurfing): Executing multiple deposits or withdrawals just below the KYC Tier thresholds in an attempt to evade higher verification.
• Pass-Through Accounts: Depositing capital into the Platform and quickly initiating a withdrawal without engaging the funds in any MIDAS investment plans, indicating the use of Meveridge merely as a clearing or mixing mechanism.
• Mixer / Tumbler Origins: Incoming deposits originating from known cryptocurrency mixer services (e.g., Tornado Cash) designed to obfuscate the source of funds.
• Unjustified Rank Advancement: Rapid, unnatural advancement through the MENTOR Leader Ranks without matching authentic community growth, indicating potential multi-accounting or circular fund transfers to artificially inflate Team Volume (TV).
• Third-Party Funding: Deposits originating from completely unrelated third parties, or requests to withdraw funds to wallets not previously verified by the User.

7.1. If AI GUARD flags a transaction or user behavior, the account is escalated to a human investigator within the Compliance Department.

7.2. During investigation, the User's Account may be temporarily suspended. Meveridge reserves the right to request clarifying information regarding the flagged transaction.

7.3. If reasonable suspicion of illicit activity remains after the internal investigation, the Compliance Officer will draft and file a Suspicious Activity Report (SAR) with the relevant Financial Intelligence Unit (FIU) or equivalent regulatory body in the applicable jurisdiction.

7.4. "Tipping Off" Prohibition:By law, Meveridge is prohibited from informing the User that an investigation is underway or that a SAR has been or will be filed. If your account is frozen pending an investigation, support staff will only advise that the account is under "routine compliance review."

8.1. Meveridge screens all Users during the KYC process and continuously thereafter against global PEP databases.

8.2. A PEP is an individual who is or has been entrusted with a prominent public function, as well as their immediate family members and close associates. PEPs present a higher risk for potential involvement in bribery and corruption.

8.3. If a User is identified as a PEP, they are automatically elevated to a High-Risk categorization and must undergo Enhanced Due Diligence (EDD), including Source of Wealth verification, regardless of their intended deposit tier. Executive management approval is required to establish or maintain a relationship with a PEP.

9.1. Meveridge strictly complies with international sanctions programs. We do not engage in business with individuals, entities, or wallets listed on major sanctions evasion lists.

9.2. Automated daily screening is conducted against:

• Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List (USA).
• Consolidated List of Persons, Groups, and Entities Subject to EU Financial Sanctions.
• United Nations Security Council Consolidated List.
• Her Majesty's Treasury (HMT) sanctions lists (UK).

9.3. If a User or their associated wallet is determined to be a sanctioned party, Meveridge will immediately freeze the Account, block all transactions, and report the assets to the relevant authorities, without prejudice or prior notification to the User.

10.1. Meveridge does not accept clients, permit Account registrations, or process transactions originating from certain geographical regions.

10.2. FATF Black List:We strictly prohibit Users residing in jurisdictions recognized by the Financial Action Task Force as "High-Risk Jurisdictions subject to a Call for Action" (e.g., Democratic People's Republic of Korea, Iran).

10.3. Comprehensive Sanctions: We also prohibit engagement with jurisdictions under comprehensive embargoes.

10.4. The list of prohibited jurisdictions is dynamically updated based on global regulatory shifts. Attempting to bypass geolocation blocks using VPNs or proxy servers to hide residence in a prohibited jurisdiction will result in immediate Account termination.

11.1. In alignment with global financial standards, Meveridge maintains comprehensive records of all User interactions and transactions.

11.2. The following data is retained for a minimum period of five (5) to seven (7) years following the closure of an Account or the termination of the business relationship, depending on the governing jurisdiction:

• Copies of all KYC/CDD documentation (IDs, Proof of Address, selfies).
• Transaction history (deposits, investments, yield accruals, withdrawals).
• Internal correspondence and AI GUARD investigation logs.
• Records of any SARs filed internally or externally.

11.3. These records are stored securely, utilizing AES-256 encryption, and are readily accessible to respond to lawful subpoenas or regulatory audits.

12.1. A robust compliance culture is foundational to our AML/CFT policy.

12.2. All Meveridge employees and contractors, particularly those in support, risk management, and operations, must complete mandatory AML/CFT training upon onboarding.

12.3. Annual refresher training is obligatory to ensure the team is updated on evolving financial crime typologies, changes to FATF recommendations, and platform-specific vulnerabilities.

13.1. Users who fail to comply with requests for KYC updates, refuse to provide Source of Funds documentation when requested under EDD, or actively engage in circumvention tactics will be restricted from accessing the Platform.

13.2. Actions Meveridge may take include:

• Rejection of incoming deposits.
• Suspension of the ability to execute new MIDAS investment plans.
• Freezing of the Available Balance and suspension of withdrawal rights.
• Permanent termination of the MENTOR affiliate structure and confiscation of pending commissions.
• Closure of the Account and return of residual principal (if legally permissible and not subject to investigative seizure).

14.1. The Chief Compliance Officer (CCO) is responsible for the oversight, implementation, and continual assessment of this Policy.

14.2. This AML & CFT Policy is subject to rigorous annual review, or ad-hoc revisions whenever significant changes in global regulatory frameworks, platform products (e.g., introduction of new investment mechanics), or threat landscapes occur.

14.3. Meveridge reserves the right to implement changes immediately if necessary to protect the platform's security and regulatory standing. Substantial changes will be communicated to Users via the LUMI News section.

*This document defines the strict operational boundaries regarding financial crime prevention on the Meveridge Platform. By utilizing our services, you expressly consent to all background checks, monitoring protocols, and verification requirements outlined herein.*