1. Policy objective
TVK Labs maintains a risk-based framework intended to prevent use of ENTELΞKRON services for money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud, theft, market abuse or other financial crime.
2. Customer due diligence
CDD may include identity verification, address verification, date of birth, nationality, legal capacity, corporate registration, directors, authorised representatives, beneficial owners and purpose/nature of the relationship.
3. Beneficial ownership
Entities may be required to identify and verify ultimate beneficial owners and control persons. Nominee, trust, foundation, partnership or complex ownership structures may require additional documentation.
4. PEP and adverse-media screening
Politically exposed persons, family members and known close associates may be subject to enhanced due diligence, senior approval and source-of-wealth/source-of-funds review where required. Relevant adverse information may be considered as part of risk assessment.
5. Sanctions screening
Applicants, beneficial owners, counterparties and relevant wallet activity may be screened against applicable UK, UN, EU and other legally relevant sanctions lists. Access or transactions may be blocked, rejected, frozen or reported where required by law.
6. Enhanced due diligence
EDD may apply to high-risk jurisdictions, unusual transaction patterns, complex ownership, high-value activity, PEP exposure, high-risk counterparties, privacy-enhancing tools, mixers/tumblers, darknet exposure, stolen-fund indicators or other elevated risk factors.
7. Source of funds and source of wealth
Participants may be required to demonstrate the legitimate origin of funds or wealth using bank statements, transaction records, sale agreements, tax records, payroll information, audited accounts, blockchain provenance or other appropriate evidence.
8. Wallet and blockchain screening
Where technically and legally appropriate, public wallet addresses and transactions may be screened for sanctions, fraud, theft, ransomware, scam, mixer, darknet, exploit or other risk indicators. Blockchain analytics are risk tools and do not replace human judgement.
9. Transaction monitoring
Monitoring may include amount, frequency, velocity, geographic indicators, source/destination, asset/network, behavioural anomalies and deviations from expected activity. Alerts may trigger requests for information, delay or rejection.
10. Travel Rule
Where a regulated virtual-asset transfer falls within applicable Travel Rule requirements, required originator and beneficiary information must be collected, verified, transmitted or received according to the applicable legal regime and service-provider role.
11. Suspicious activity and reporting
Where legally required, suspicious activity may be reported to the relevant financial-intelligence unit or competent authority. We may be legally prohibited from informing the affected person that a report or investigation exists.
12. Record keeping
CDD, transaction, screening, risk-assessment and decision records are retained for the period required by applicable law and legitimate compliance needs, subject to data-protection principles.
13. Reliance and outsourcing
Third-party KYC, screening or blockchain-analysis vendors may support the process, but outsourcing does not remove legal responsibility where TVK Labs is the responsible regulated or contractual party.
14. Ongoing monitoring and refresh
KYC is not necessarily a one-time event. Information may be refreshed when documents expire, ownership changes, risk increases, transaction behaviour changes or legal requirements evolve.
15. Refusal and termination
We may refuse onboarding, suspend transactions, reject payment, withhold token delivery, terminate access or request additional evidence where risk cannot be satisfactorily resolved, subject to applicable contractual and legal duties.
16. Anti-bribery and corruption
Bribery, kickbacks, facilitation payments and corrupt inducements are prohibited. Partners and service providers may be subject to integrity and conflict-of-interest due diligence.
17. Staff, governance and escalation
Compliance responsibilities, escalation routes and approval thresholds should be documented internally, with access to relevant records and senior review for higher-risk cases.
18. No circumvention
Structuring transactions, using nominees, multiple accounts, VPNs, intermediaries or wallet hopping to evade eligibility, sanctions, limits or monitoring is prohibited.
19. Contact
Compliance enquiries: legal@tvk.group. Do not send seed phrases, private keys or unnecessary sensitive documents by unapproved channels.
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