AML / CFT Policy

1. Purpose and Scope

This Anti-Money Laundering and Counter-Financing of Terrorism Policy ("AML/CFT Policy") sets out the obligations and standards adopted by WISCE Technologies Ltd. to detect, prevent, and report money laundering and terrorist financing activities.

This policy applies to all operations of WISCE Technologies Ltd., including the WISCE Wallet software, web application, and any services we offer directly or through third-party integrations.

2. Legal Framework

WISCE complies with applicable AML/CFT regulations in all jurisdictions where we operate, including but not limited to:

• The Bank Secrecy Act (BSA) and FinCEN regulations (United States)
• The EU's Anti-Money Laundering Directives (AMLD)
• FATF (Financial Action Task Force) Recommendations
• Applicable national laws in the 40+ countries where we operate

3. Non-Custodial Nature and AML Obligations

WISCE is a non-custodial wallet provider. We do not hold user funds, control private keys, or process transactions on users' behalf. Transactions on public blockchain networks are executed directly by users and recorded on immutable public ledgers.

While our non-custodial architecture limits direct exposure to traditional financial crime risks, we recognize our responsibility within the broader ecosystem and maintain the following standards:

• We do not knowingly facilitate transactions involving sanctioned individuals, entities, or jurisdictions.
• We screen our integrated third-party services (DEX aggregators, staking providers) against regulatory requirements.
• We cooperate fully with law enforcement and regulatory authorities as required by law.

4. Prohibited Activities

WISCE Wallet must not be used for:

• Money laundering in any form, including placement, layering, or integration of illicit funds.
• Financing terrorism or violent extremism.
• Circumventing sanctions administered by OFAC, the UN Security Council, the EU, or other relevant bodies.
• Operating in jurisdictions under comprehensive U.S. or EU sanctions (currently including Iran, North Korea, Cuba, Syria, and the Crimea/DNR/LNR regions).
• Structuring transactions to evade reporting thresholds ("smurfing").
• Any other activity prohibited by applicable law.

5. Risk-Based Approach

WISCE applies a risk-based approach to compliance, focusing resources on higher-risk areas while maintaining a frictionless experience for the vast majority of legitimate users. Risk factors we consider include:

• Geographic risk — jurisdictions with elevated AML/CFT risk profiles.
• Transaction pattern risk — unusual transaction sizes or frequencies.
• Counterparty risk — interactions with known high-risk addresses or protocols.

6. Transaction Monitoring

While WISCE does not process transactions directly, we employ blockchain analytics tools to monitor for patterns associated with financial crime on our platform. We screen wallet addresses against global sanctions lists and known illicit address databases.

When suspicious activity is detected, WISCE may:

• Restrict access to WISCE-operated services (such as fiat on-ramps or integrated swaps).
• File a Suspicious Activity Report (SAR) with FinCEN or equivalent regulatory body.
• Cooperate with law enforcement investigations.

7. Third-Party Partners

WISCE conducts due diligence on all third-party partners integrated into our platform. We require that partners maintain AML/CFT programs commensurate with applicable law and our standards. Partners who fail to maintain adequate compliance programs will be removed from our platform.

8. Record Keeping

WISCE maintains records of all compliance-related decisions, suspicious activity reports, and law enforcement responses for a minimum of 5 years, or as required by applicable law.

9. Training and Awareness

All WISCE employees and contractors with access to compliance-relevant systems receive regular AML/CFT training. Our compliance program is reviewed and updated annually or upon material regulatory changes.

10. Reporting Concerns

If you have reason to believe that WISCE Wallet is being used for money laundering, terrorism financing, or other illegal activities, please report it immediately:

• Email: contact@wiscewallet.com (subject: "AML REPORT")
• Phone: (571) 639-3988

Reports are treated with strict confidentiality. Whistleblowers are protected from retaliation.

11. Policy Updates

This AML/CFT Policy is reviewed at least annually and updated to reflect changes in law, regulation, or best practices. Material updates will be communicated to users and published on this page.