AML Policy — InvCo Funds

Zero Tolerance: InvCo Funds has a zero-tolerance policy toward money laundering, terrorist financing, and any other form of financial crime. We are committed to full compliance with applicable AML and KYC regulations across all jurisdictions in which we operate.

1. Our Commitment to Financial Integrity

InvCo Funds Ltd. is committed to preventing the use of our platform for money laundering, terrorist financing, tax evasion, and other financial crimes. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the procedures and controls we have implemented to detect, prevent, and report suspicious financial activity.

This policy applies to all users of the InvCo Funds platform, all staff members, and all third-party service providers who access or process user data on our behalf. Compliance with this policy is mandatory and non-negotiable.

Our AML/KYC program is designed in accordance with the Financial Action Task Force (FATF) recommendations, the EU's Anti-Money Laundering Directives (AMLD5/6), and applicable national legislation in the United Kingdom and other jurisdictions where we operate.

2. AML Compliance Framework

Our AML program is built on four core pillars that work together to create a robust defense against financial crime:

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Customer Due Diligence

Verifying the identity of all users through KYC procedures before allowing deposits or withdrawals above threshold amounts.

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Transaction Monitoring

AI-powered real-time monitoring of all transactions for unusual patterns, structuring, and other indicators of illicit activity.

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Suspicious Activity Reporting

Prompt reporting of suspicious transactions to relevant financial intelligence units as required by applicable law.

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Record Keeping

Maintaining comprehensive records of all KYC documentation, transactions, and compliance decisions for the legally required period.

3. Know Your Customer (KYC) Requirements

InvCo Funds applies a risk-based approach to KYC. The level of due diligence required depends on the transaction amounts and risk profile of the user:

3.1 Standard Due Diligence (All Users)

Full legal name as it appears on government-issued identification
Valid email address (verified through OTP confirmation)
Country of residence
Phone number
Acknowledgment of Terms of Service and Risk Disclosure

3.2 Enhanced Due Diligence (High-Value Investors)

Users whose cumulative deposits exceed $10,000 or who are identified as high-risk may be required to provide:

Government-issued photo identification (passport, national ID card, or driver's license)
Proof of address (utility bill or bank statement dated within 3 months)
Source of funds declaration — a brief explanation of the origin of the invested capital
Source of wealth documentation for investments exceeding $50,000

3.3 Politically Exposed Persons (PEPs)

Users identified as Politically Exposed Persons — individuals who hold or have held prominent public positions — are subject to enhanced due diligence regardless of investment amount. InvCo Funds screens all users against global PEP databases upon registration and periodically thereafter.

4. Verification Process

Our KYC verification process is straightforward and typically completed within 24 hours:

Account Registration

User provides basic information and verifies email address via OTP. Standard due diligence is completed automatically at this stage.

Identity Screening

All registered users are automatically screened against global sanctions lists, PEP databases, and adverse media databases within minutes of registration.

Enhanced Verification (if triggered)

Users flagged for enhanced due diligence are contacted via email with a document request. Deposits may be held pending verification completion.

Document Review

Our compliance team reviews submitted documents within 24 business hours. Users are notified by email of approval, rejection, or any additional requirements.

Ongoing Monitoring

Verified users are subject to continuous transaction monitoring and periodic re-verification to ensure their profile remains current and accurate.

5. Transaction Monitoring

InvCo Funds employs automated transaction monitoring systems that analyze all deposits, withdrawals, and investment activities in real time. Our monitoring system flags transactions that exhibit any of the following characteristics:

Deposits structured just below reporting thresholds (structuring / smurfing)
Rapid cycling of funds without apparent investment purpose
Multiple accounts originating from the same IP address or device
Deposits from high-risk jurisdictions or sanctioned countries
Withdrawal requests to wallets associated with known illicit activity
Unusual transaction patterns inconsistent with the user's stated profile

Flagged transactions are reviewed by our compliance team within 4 hours. Where necessary, transactions may be placed on hold pending investigation.

6. Red Flag Indicators

The following behaviors and patterns are treated as red flags and may trigger enhanced scrutiny, account suspension, or mandatory reporting:

🚩User is reluctant to provide KYC documentation or provides inconsistent information across different interactions

🚩Funds deposited appear to originate from multiple unrelated wallet addresses in rapid succession

🚩User requests withdrawal to a different wallet than previously used without adequate explanation

🚩Investment amounts are inconsistent with the user's stated occupation or financial profile

🚩User mentions that funds are on behalf of a third party or that someone else is funding the account

🚩Blockchain analytics tools identify deposits as originating from mixing services, darknet markets, or other high-risk sources

🚩User creates multiple accounts or attempts to circumvent verification procedures

🚩Rapid deposit-and-withdraw behavior with no interest in investment returns

7. Suspicious Activity Reporting

Where InvCo Funds identifies transactions or behaviors that are reasonably suspected to involve money laundering or terrorist financing, we are legally obligated to file a Suspicious Activity Report (SAR) or equivalent report with the relevant financial intelligence unit in our jurisdiction.

⚠ Tipping Off Prohibition: In accordance with AML legislation, InvCo Funds staff are prohibited from informing users that they have been or may be reported to law enforcement authorities. Any such disclosure constitutes a criminal offense known as "tipping off."

Users whose accounts are under investigation will not receive specific reasons for account holds or transaction delays. We are legally required to maintain confidentiality regarding ongoing compliance investigations.

8. Sanctions Screening

InvCo Funds screens all users and transactions against major global sanctions lists, including but not limited to:

United Nations Security Council consolidated sanctions list
UK HM Treasury financial sanctions list
US OFAC Specially Designated Nationals (SDN) list
EU consolidated list of persons, groups, and entities subject to financial sanctions
Global PEP and adverse media databases

Any match against these lists will result in immediate account suspension and may result in mandatory reporting to relevant authorities. Sanctions screening is performed at registration, upon each transaction, and periodically for all active accounts.

9. Record Keeping

InvCo Funds maintains comprehensive records in compliance with applicable AML legislation:

KYC documentation: Retained for a minimum of 5 years from the date of account closure
Transaction records: Retained for a minimum of 7 years from the date of each transaction
SAR filings: Retained for a minimum of 5 years from the date of filing
Compliance decisions: All compliance officer decisions, including rationale, retained for 5 years
Training records: Staff AML training records retained for the duration of employment plus 3 years

All records are stored securely with access restricted to authorized compliance personnel only. Records may be provided to law enforcement or regulatory authorities upon receipt of a lawful request.

10. Staff Training

All InvCo Funds staff with access to user data or financial systems receive mandatory AML/KYC training:

Comprehensive AML induction training upon joining the company
Annual refresher training covering regulatory updates and emerging typologies
Targeted training following any SAR filing or compliance incident
Regular updates on new money laundering techniques and typologies relevant to cryptocurrency

Our Money Laundering Reporting Officer (MLRO) oversees the AML program and is responsible for receiving internal suspicion reports, making SAR decisions, and liaising with law enforcement as required.

11. Enforcement & Consequences

Violations of this AML/KYC policy will be treated with utmost seriousness. Consequences for policy violations include:

Immediate account suspension pending investigation
Permanent account termination and blacklisting from the platform
Forfeiture of any funds identified as proceeds of crime
Mandatory reporting to law enforcement and financial intelligence authorities
Full cooperation with any criminal investigation or prosecution

⚠ Criminal Liability: Money laundering and terrorist financing are serious criminal offenses carrying significant prison sentences in most jurisdictions. InvCo Funds will cooperate fully with law enforcement investigations and will not protect users engaged in financial crime.

12. Contact Our Compliance Team

For AML/KYC inquiries, document submission, or compliance-related questions, please contact our dedicated compliance team:

Compliance Email: compliance@invco.live
MLRO Direct: mlro@invco.live
General Support: support@invco.live
Address: InvCo Funds Ltd., Compliance Department, London, United Kingdom

Our compliance team is available Monday–Friday, 9:00 AM – 6:00 PM GMT. For urgent compliance matters, our 24/7 support team can escalate to the on-call compliance officer.

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AML / KYC Policy