Compliance Policy

1. Introduction

At Milestone Finance, we are committed to maintaining the highest standards of regulatory compliance and ethical business practices. This Compliance Policy outlines our approach to ensuring that our platform operates in accordance with applicable laws, regulations, and industry standards related to cryptocurrency and blockchain technology.

We believe that regulatory compliance is not just a legal obligation but a foundational element of building trust with our users, partners, and the broader community. This policy reflects our commitment to creating a secure, transparent, and compliant environment for all participants in the Milestone ecosystem.

2. Anti-Money Laundering (AML) Compliance

Our Anti-Money Laundering program is designed to prevent the use of our platform for money laundering, terrorist financing, and other financial crimes. Our AML framework includes:

2.1 Customer Due Diligence (CDD)

We conduct appropriate due diligence on all users before they can access certain features of our platform. This process may include:

• Verifying user identity through reliable and independent sources
• Determining the nature and purpose of business relationships
• Enhanced Due Diligence (EDD) for higher-risk users or transactions
• Ongoing monitoring to ensure account activity is consistent with expected behavior

2.2 Transaction Monitoring

We employ automated systems to monitor transactions for suspicious activity. Our monitoring includes:

• Detection of unusual transaction patterns
• Identification of transactions that exceed certain thresholds
• Screening against sanctions lists and known high-risk entities
• Blockchain analytics to assess source and destination of funds

2.3 Suspicious Activity Reporting

We promptly report suspicious activities to the appropriate regulatory authorities in accordance with applicable laws and regulations. Our employees are trained to recognize red flags that may indicate suspicious activity.

3. Know Your Customer (KYC) Procedures

Our KYC procedures are designed to verify the identity of our users and assess their risk profile. These procedures help us prevent fraud, monitor for suspicious activity, and comply with regulatory requirements.

3.1 Identity Verification Levels

We implement a risk-based approach with tiered verification levels:

• Basic Verification: Email and phone number verification for limited platform access
• Standard Verification: Government-issued ID, proof of address, and facial recognition for standard transaction limits
• Enhanced Verification: Additional documentation or information for higher transaction limits or certain services

3.2 Documentary Evidence

We may require the following documents or information as part of our KYC process:

• Government-issued photo identification (passport, driver's license, ID card)
• Proof of address (utility bill, bank statement, official government correspondence)
• Source of funds declaration for larger transactions
• Additional information based on risk assessment or regulatory requirements

3.3 Ongoing KYC Maintenance

We periodically review and update user information to ensure accuracy and relevance. Users may be required to provide updated documentation or additional information over time.

4. Sanctions Compliance

We are committed to complying with all applicable sanctions programs, including those administered by the U.S. Office of Foreign Assets Control (OFAC), the United Nations Security Council, the European Union, and other relevant authorities.

Our sanctions compliance program includes:

• Screening users against global sanctions lists
• Monitoring and blocking transactions involving sanctioned jurisdictions, entities, or individuals
• Regular updates to our sanctions screening databases
• IP blocking and geolocation verification to prevent access from restricted jurisdictions

5. Prohibited Activities and Jurisdictions

5.1 Prohibited Activities

The following activities are strictly prohibited on our platform:

• Money laundering or attempts to conceal the origins of illegally obtained funds
• Terrorist financing
• Fraud or deceptive practices
• Tax evasion
• Trade in illegal goods or services
• Violation of sanctions or embargoes
• Transactions related to high-risk or illegal businesses

5.2 Restricted Jurisdictions

Due to regulatory constraints, we may restrict or prohibit access to our services from certain jurisdictions. The list of restricted jurisdictions may change based on evolving regulatory requirements. We maintain technical measures to prevent users from restricted jurisdictions from accessing our platform.

Users are responsible for ensuring that their use of our services complies with local laws and regulations in their jurisdiction.

6. Data Protection and Privacy

We are committed to protecting user data and privacy while meeting our compliance obligations. Our approach includes:

• Collecting only necessary information for compliance purposes
• Implementing secure storage and processing of sensitive personal information
• Maintaining appropriate data retention periods
• Providing user access to their personal information
• Ensuring all data handling complies with applicable data protection laws

For complete information about our data practices, please refer to our Privacy Policy.

7. Compliance Training and Governance

7.1 Staff Training

All Milestone Finance team members receive regular training on:

• Anti-money laundering requirements
• KYC procedures
• Sanctions compliance
• Identifying and reporting suspicious activity
• Data protection and privacy
• Emerging regulatory trends and requirements

7.2 Compliance Governance

Our compliance governance structure includes:

• A dedicated Compliance Officer responsible for overseeing our compliance program
• Regular risk assessments and program evaluations
• Documented policies and procedures
• Independent reviews and testing
• Board and management oversight

8. Regulatory Cooperation

We are committed to cooperating with regulatory authorities and law enforcement agencies when required by law. This includes:

• Responding to lawful requests for information
• Filing required reports and disclosures
• Implementing necessary changes to comply with new regulations
• Maintaining open channels of communication with relevant authorities

9. Licensing and Registration

We seek to obtain and maintain appropriate licenses and registrations in jurisdictions where our activities require regulatory authorization. We continuously monitor regulatory developments and adapt our operations to comply with evolving requirements.

Information about our current licenses and registrations is available upon request.

10. Blockchain Compliance Monitoring

We utilize specialized blockchain analytics tools and techniques to:

• Analyze transaction patterns and identify suspicious activity
• Trace the source and destination of funds
• Identify connections to high-risk addresses or services
• Monitor for transactions involving mixing services, dark web markets, or other high-risk sources

11. Policy Updates

This Compliance Policy will be reviewed and updated regularly to reflect changes in regulatory requirements, industry standards, and our business operations. We will notify users of significant changes to this policy through our website or other communication channels.

12. Contact Information

If you have questions about our compliance policies or procedures, please contact our compliance team at:

13. Whistleblower Protection

We encourage reporting of any suspected violations of this policy, applicable laws, or regulations. We prohibit retaliation against any individual who, in good faith, reports suspected violations or participates in an investigation of reported violations.

Reports can be made confidentially to our compliance team or through our anonymous reporting channel.