AML · KYC Policy

1. Regulatory Governance and Standards

VISHAB OTC, S.A. de C.V. enforces strict zero-tolerance policies regarding Money Laundering, Terrorist Financing, and Proliferation Financing (AML/CFT/CPF). Our compliance program is established pursuant to:

• The Digital Assets Issuance Law (LEAD) and the RPSAD Regulation of El Salvador.
• The Anti-Money Laundering and Asset Forfeiture Law (LCLDA) and relevant regulatory directives of the Financial Investigation Unit (FIU/UIF).
• The Financial Action Task Force (FATF/GAFI) 40 Recommendations, with particular emphasis on Recommendations 15 and 16 (Virtual Assets and Travel Rule).

2. Customer Due Diligence (KYB / KYC)

Prior to the execution of any trading relationship or onboarding:

• Corporate Due Diligence (KYB): All counterparties undergo mandatory Know Your Business checks, including verification of constitutional legal standing, corporate registry records, good standing, and the identification of all Ultimate Beneficial Owners (UBOs) holding 10% or more of shareholding or voting rights.
• Sanctions Screening: VISHAB OTC strictly refuses business relationships with any natural or legal person listed on international sanctions databases, including OFAC (US), UN Security Council, European Union (EU), and HM Treasury (UK) consolidated lists.
• Politically Exposed Persons (PEPs): Enhanced Due Diligence (EDD) protocols and Chief Compliance Officer (CCO) sign-offs are mandatory for all transactions involving PEPs or high-risk jurisdictions.

3. Transaction Monitoring and Blockchain Forensics (KYT)

All institutional operations are audited under an automated compliance framework:

• Proprietary AML Engine: Real-time transaction surveillance rules (RT) monitoring order velocity, address consistency, and structuring patterns.
• Forensic Blockchain Intelligence (Know-Your-Transaction / KYT): Continuous on-chain risk scoring for all cryptocurrency transactions above the statutory threshold of USD 1,000. Wallet addresses tainted by associations with illicit marketplaces, sanctions, ransomware, exploits, or unverified mixer protocols are automatically rejected.
• Exclusion of Privacy Coins: Under applicable regulatory parameters, VISHAB OTC explicitly prohibits and rejects transactions involving anonymized or untraceable privacy assets (including Monero and Zcash).

4. Travel Rule Compliance

Pursuant to Salvadoran Executive Decree No. 426 and FATF Recommendation 16:

• For digital asset transfers equivalent to or exceeding USD 1,000, VISHAB OTC securely captures, verifies, and transmits complete originator and beneficiary identifying data to counterparty Virtual Asset Service Providers (VASPs/PSADs).
• Transactions involving self-hosted or unhosted wallets are subject to mandatory wallet ownership verification proofs prior to on-chain execution and settlement.

5. Suspicious Activity Reporting

VISHAB OTC maintains proactive collaboration with the competent regulatory authorities in El Salvador. Any transaction deemed suspicious or unsupported by demonstrable commercial legitimacy will be immediately reported to the Financial Investigation Unit (FIU/UIF) and the CNAD in accordance with statutory reporting obligations, strictly respecting anti-tipping-off rules.