ApeTops US Inc. is committed to preventing money laundering, terrorist financing, and other financial crime. Although we are not a financial institution, we align our customer-onboarding and payment controls with the spirit of the Bank Secrecy Act of 1970 (the "BSA") and guidance issued by the Financial Crimes Enforcement Network ("FinCEN") and the Office of Foreign Assets Control ("OFAC").
1. Program Overview
Our compliance program is approved and overseen by senior management. The program is documented, periodically reviewed, and updated to reflect regulatory changes, new product offerings, and emerging risk indicators. We maintain books and records sufficient to demonstrate compliance for a minimum of five (5) years.
2. Customer Due Diligence (CDD) and KYC
Before onboarding a customer, we collect and verify information sufficient to identify the business entity and its beneficial owners (for entities owning 25% or greater, and at least one control person). We perform screening against OFAC's Specially Designated Nationals list, other sanctions programs, and politically-exposed-person databases. Enhanced Due Diligence is applied to customers that present elevated risk (for example, non-U.S. parent entities, high-risk jurisdictions, or novel payment arrangements).
3. Sanctions and Export Controls
We do not provide Services, directly or indirectly, to any person, entity, or jurisdiction subject to comprehensive U.S. sanctions, including Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions. We also comply with export-control obligations under the Export Administration Regulations (EAR), including applicable restrictions on advanced GPU compute.
4. Ongoing Monitoring and SAR Filings
We monitor customer activity and payment patterns for indicia of suspicious behavior. Unusual activity is escalated to our compliance officer for review. Where applicable and required, we will cooperate with law-enforcement requests and support the filing of a Suspicious Activity Report (SAR) by a payment partner or directly with FinCEN.
5. Training and Contact
All employees who interact with customers or payments receive AML training at hire and at least annually thereafter. Questions or concerns can be directed to our compliance team at compliance@apetops-us.com or by mail to 1209 N Orange St, Wilmington, DE 19801.