AML and KYC policy
Last updated 14 October 2026
Template for legal review. This document is a starting point and must be adapted by a qualified lawyer to the jurisdictions where Zarkoin operates before launch. Text in [brackets] needs to be completed.
Our commitment
Zarkoin does not tolerate money laundering, terrorist financing, fraud or sanctions evasion. This policy describes the controls we apply. [Adapt to the applicable regulator’s requirements.]
Customer due diligence
- Level 0: email or phone verification. Limited withdrawals.
- Level 1: government-issued photo ID and a selfie, reviewed manually by our compliance team.
- Level 2: proof of address (utility bill or bank statement under 3 months old).
We may request additional information, including source of funds, at any time.
Sanctions screening
Customers are screened against applicable sanctions lists at onboarding and on an ongoing basis. Accounts linked to sanctioned persons or jurisdictions are blocked.
Transaction monitoring
We monitor deposits, withdrawals, trades and P2P activity for unusual patterns, such as rapid movement of funds with no trading purpose, structuring below limits, or use of third-party payment accounts in P2P. Large or unusual withdrawals are reviewed by staff before processing.
Blockchain analytics
[Optional: describe on-chain screening of deposit sources and withdrawal destinations.]
Reporting
Where required, we report suspicious activity to the relevant financial intelligence unit and may be prohibited from telling the customer.
Record keeping
Identity documents and transaction records are retained for at least [5] years after the end of the business relationship.
Training and governance
Staff with customer or compliance responsibilities receive regular training. A designated compliance officer oversees this policy. [Insert name or title.]