AML / KYC Policy

Effective date: October 28, 2026

1. Our commitment

Astro Breeze LLC ("Astro Breeze") maintains a documented, risk-based anti-money-laundering ("AML") program designed to prevent the use of our Services for money laundering, terrorist financing, sanctions evasion and other financial crime. The program applies equally to fiat and stablecoin flows.

2. Governance and training

The program is owned by our designated compliance officer, approved by management, reviewed at least annually, and supported by ongoing training for all staff with client-facing or payment-processing responsibilities.

3. Know your business (KYB) and customer identification

Before any Services are activated, we verify: the legal entity and its formation documents; ownership and control structure; beneficial owners and controlling persons (including government-issued identification and proof of address); the purpose and expected activity of the account; and, where applicable, licenses held by the client.

We do not open or operate anonymous accounts, and we do not provide Services to shell banks or entities with unverifiable ownership structures.

4. Sanctions, PEP and adverse-media screening

All applicants, beneficial owners and counterparties are screened against sanctions lists (including OFAC and applicable international lists) and for politically-exposed-person and adverse-media status, at onboarding and on an ongoing basis. Potential matches are reviewed and, where required, blocked, rejected or reported.

5. Transaction monitoring

Client activity is monitored against the expected profile established at onboarding, using automated rules calibrated to product, corridor and volume risk. Alerts are reviewed by compliance staff; escalations may result in information requests, restrictions, suspension or termination of the relationship, and reporting where required.

6. Enhanced due diligence

Higher-risk clients and corridors — including complex ownership structures, high-volume stablecoin activity, and higher-risk jurisdictions — are subject to enhanced due diligence, including source-of-funds and source-of-wealth information and senior approval before onboarding or continued service.

7. Prohibited industries and geographies

A defined prohibited-industry list applies to all applicants, including unlicensed money transmission, unregistered securities activity, illicit-goods marketplaces and sanctions-linked parties. Certain jurisdictions are not supported or are supported only under enhanced due diligence. The current lists are provided during onboarding and updated from time to time.

8. Recordkeeping and cooperation

Identity, onboarding and transaction records are retained for at least five years after the end of the client relationship, or longer where required. We cooperate with competent authorities and respond to lawful requests, including subpoenas and regulatory examinations.

9. Independent review

The program is subject to periodic independent review, with findings and remediation tracked to completion.

10. Questions

Compliance inquiries: [email protected].