# AML & KYC ## **1. Introduction and Purpose** XRPSCAN Pte. Ltd. ("the Company") is committed to the highest standards of financial integrity and regulatory compliance in the conduct of its business. This Anti-Money Laundering ("AML") and Know Your Customer ("KYC") Policy sets out the framework, procedures, and obligations that govern the Company's approach to preventing money laundering, terrorist financing, and other financial crimes across all its commercial activities. The Company operates XRPSCAN, a block explorer and data services platform for the XRP Ledger, and generates revenue through advertising partnerships and paid API subscriptions. All commercial relationships entered into by the Company are subject to the compliance procedures described in this Policy. ## **2. Regulatory Framework** The Company is incorporated in Singapore and conducts its operations in compliance with applicable Singapore laws and regulations, including the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act ("CDSA"), the Terrorism (Suppression of Financing) Act ("TSOFA"), and the guidelines issued by the Monetary Authority of Singapore ("MAS") relating to the prevention of money laundering and countering the financing of terrorism ("AML/CFT"). The Company also takes cognizance of internationally recognized standards, including the Financial Action Task Force ("FATF") Recommendations, and applies risk-based compliance practices consistent with those standards when onboarding and maintaining relationships with counterparties across jurisdictions. ## **3. Customer Due Diligence** The Company conducts Customer Due Diligence ("CDD") on all clients and commercial counterparties prior to entering into a business relationship. CDD procedures are applied uniformly and are calibrated to the assessed risk level of each counterparty. For corporate clients, including advertising partners, API subscribers, and development clients - the Company applies Know Your Business ("KYB") procedures, which include verification of the entity's legal registration and the nature of the business. Enhanced Due Diligence ("EDD") is applied to counterparties that present higher risk profiles, including those incorporated in high-risk or non-cooperative jurisdictions as identified by FATF, Politically Exposed Persons ("PEPs") and their associates, and clients whose business activities or transaction patterns deviate materially from expected norms. EDD may include additional documentation requests, senior management approval, and ongoing enhanced monitoring. The Company will not enter into or maintain a business relationship with any entity or individual that is on the US sanctions list. ## **4. Compliance Platform: Impact** Commercial transactions, payment processing, and compliance verification for XRPSCAN's business activities are conducted through Impact, a regulated compliance and payments platform. Impact provides integrated KYC, KYB, and AML screening capabilities that underpin the Company's compliance framework. The use of Impact ensures that the Company maintains robust, auditable compliance records for all commercial relationships, supporting its obligations under Singapore law and providing a reliable evidence base in the event of regulatory inquiry. ## **5. Sanctions Screening and Prohibited Counterparties** The Company maintains a strict policy of not doing business with individuals, entities, or jurisdictions subject to international sanctions. Prior to onboarding any client, the Company screens counterparty names and associated persons against applicable sanctions lists, including those maintained by the US Office of Foreign Assets Control ("OFAC"), the United Nations Security Council, the European Union, and the Monetary Authority of Singapore. The Company will immediately terminate any existing relationship and freeze associated transactions if a counterparty is identified as a sanctions-listed entity or individual. Any such occurrence will be reported to the relevant authorities in accordance with applicable law. ## **6. Transaction Monitoring and Suspicious Activity** The Company monitors its commercial transactions on an ongoing basis for patterns or activity that may indicate money laundering, terrorist financing, or other financial crime. Indicators of suspicious activity include, but are not limited to, unusual payment structures, payments from or to unrelated third parties, requests to circumvent standard CDD procedures, and clients who are unwilling or unable to provide satisfactory documentation. The Company maintains a strict non-tipping-off policy. No client or counterparty will be informed that they are under investigation or that a report has been made to the authorities. ## **7. Record Keeping** The Company retains all CDD and KYB documentation, transaction records, compliance screening results, and related correspondence for a minimum of five years from the date of the relevant transaction or the end of the business relationship, whichever is later. Records are maintained in a secure and retrievable format and are available for production to regulatory authorities upon lawful request. ## **8. Training and Governance** The Company's directors and senior management bear ultimate responsibility for the implementation and oversight of this Policy. A designated compliance officer is appointed to manage day-to-day AML/KYC operations, oversee the Impact platform, and ensure that all staff with compliance-relevant responsibilities receive adequate training. The Policy is reviewed at least annually and updated as necessary to reflect changes in applicable law, regulatory guidance, or the Company's business activities. ## Contact Us If you have any questions about this policy, please contact us at . --- # Agent Instructions: Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. 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