KYC / AML & Sanctions Compliance Overview

Table of Contents

Introduction

Becoming Alpha, Inc. (the "Company," "we," "us," or "our") is committed to maintaining the highest standards of compliance with anti-money laundering (AML), know your customer (KYC), and economic sanctions laws and regulations. As a U.S.-based financial technology platform operating in the cryptocurrency and digital asset space, we are subject to various U.S. federal and state laws that require us to verify the identity of our users and prevent our platform from being used for illegal purposes.

This KYC / AML & Sanctions Compliance Overview explains why we collect identity verification information, how we use it, and how we comply with applicable laws. This document is designed to be user-friendly while providing transparency about our compliance obligations. For more detailed information about how we collect, use, and protect your personal information, please see our Privacy Policy.

This Overview should be read together with our Terms of Service, Privacy Policy, and Acceptable Use Policy, which contain additional information about your obligations and our practices.

When and Why We Collect Identity Verification

We collect identity verification information (KYC/KYB data) in various circumstances to comply with legal requirements and protect our platform and users from fraud and illegal activity.

When We Require Verification

We typically require identity verification when:

• Account Creation: When you create an account on Becoming Alpha, we may require basic identity verification to ensure you are a real person and meet our eligibility requirements
• Marketplace Transactions: When you engage in certain marketplace transactions (buying, selling, or trading digital assets), we may require additional verification to comply with financial regulations
• High-Value Transactions: For transactions above certain thresholds (which may vary based on applicable regulations), we typically require enhanced verification
• Suspicious Activity: If we detect suspicious or unusual activity on your account, we may request additional verification to ensure your account is secure and compliant
• Regulatory Requirements: As required by applicable laws and regulations, including the Bank Secrecy Act (BSA) and regulations issued by the Financial Crimes Enforcement Network (FinCEN)

Why We Collect This Information

We collect identity verification information for several important reasons:

• Legal Compliance: U.S. law requires financial institutions and certain cryptocurrency platforms to verify the identity of their customers to prevent money laundering, terrorist financing, and other financial crimes
• Fraud Prevention: Verifying user identities helps us prevent fraud, identity theft, and account takeover attempts
• Sanctions Compliance: We must screen all users against U.S. and international sanctions lists to ensure we do not do business with sanctioned individuals or entities
• Platform Security: Identity verification helps us maintain a secure platform and protect legitimate users from bad actors
• Regulatory Reporting: We may be required to report certain transactions or suspicious activity to regulatory authorities, which requires us to have accurate user identification information

What Information We Collect

The specific information we collect depends on the level of verification required, but typically includes:

• Personal Information: Full legal name, date of birth, residential address, email address, phone number
• Government-Issued ID: Copies of government-issued identification documents (e.g., passport, driver's license, national ID card) and verification that the ID is legitimate
• Proof of Address: Utility bills, bank statements, or other documents that verify your residential address
• Selfie or Video Verification: In some cases, we may require a selfie or live video to confirm that you are the person shown in your ID documents
• Business Information (for business accounts): For business or corporate accounts, we may collect business registration documents, tax identification numbers, and information about business owners, directors, and beneficial owners

For detailed information about what personal data we collect and how we process it, please see our Privacy Policy.

Third-Party Identity Verification Providers

We use trusted third-party identity verification service providers to assist with KYC/KYB processes. These providers are specialized companies that help us verify user identities quickly and securely while maintaining compliance with applicable laws.

How We Use Third-Party Providers:

• We securely transmit your identity verification information (ID documents, personal information, etc.) to our third-party verification provider
• The provider analyzes your documents and information to verify your identity and check for fraud indicators
• The provider returns verification results to us (e.g., "verified," "not verified," or "requires additional review")
• We use these results to make decisions about account access and transaction approvals

Third-Party Provider Security:

Our third-party verification providers are required to:

• Maintain industry-standard security measures to protect your personal information
• Comply with applicable data protection laws and regulations
• Use your information solely for identity verification purposes
• Store and retain your information only as long as necessary for verification and legal compliance

We select our verification providers carefully and require them to meet high standards for security and privacy. However, we are not responsible for the privacy practices of third-party providers, and you should review their privacy policies if you have questions about how they handle your information.

Sharing with Third Parties:

We share identity verification information with third-party providers only as necessary to perform verification services. We do not sell your identity verification information to third parties. For more information about how we share your personal information, please see our Privacy Policy.

Sanctions Screening

As a U.S.-based company, Becoming Alpha is required to comply with U.S. economic sanctions programs administered by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury. We are also committed to complying with United Nations sanctions and other international sanctions regimes where applicable.

What Are Sanctions?

Economic sanctions are restrictions imposed by governments to prohibit or limit business relationships with certain countries, entities, or individuals. Sanctions are designed to promote national security, foreign policy objectives, and international peace and security. U.S. sanctions programs prohibit U.S. persons and entities (including Becoming Alpha) from doing business with:

• Individuals and entities listed on OFAC's Specially Designated Nationals (SDN) list
• Certain countries subject to comprehensive sanctions programs
• Other individuals and entities designated under specific sanctions programs

Our Sanctions Screening Process:

We screen all users against sanctions lists:

• During Onboarding: When you create an account and during identity verification, we screen your name, date of birth, and other identifying information against OFAC and other sanctions lists
• Ongoing Monitoring: We periodically re-screen existing users against updated sanctions lists to ensure continued compliance
• Transaction Screening: For certain transactions, we may screen counterparties and transaction details against sanctions lists

What Happens If You Appear on a Sanctions List:

If our screening indicates that you, your business, or any beneficial owner of your account may be subject to sanctions:

• We will immediately suspend or terminate your account
• We will not process any pending transactions
• We may be required to report the match to OFAC or other regulatory authorities
• We will not be able to provide services to you, even if you believe you are not subject to sanctions

False Positives:

Sometimes, legitimate users may have names similar to sanctioned individuals, which can result in a "false positive" match. If you believe your account was suspended or restricted due to a false positive sanctions match, please contact us immediately. We will investigate and, if appropriate, work with you to resolve the matter and restore your account access.

However, please understand that we must be cautious in these situations. We cannot provide services if we have any reasonable doubt about sanctions compliance, as doing so could result in significant penalties and legal consequences for Becoming Alpha.

Jurisdictional Restrictions

Becoming Alpha is a U.S.-based platform, and our services may not be available in all jurisdictions. We restrict access to our platform from certain countries and regions for legal, regulatory, and compliance reasons.

Restricted Jurisdictions:

We generally do not provide services to users located in, or who are citizens or residents of, the following jurisdictions:

• Countries Subject to Comprehensive U.S. Sanctions: We are prohibited from providing services to users in countries subject to comprehensive U.S. sanctions programs, such as Cuba, Iran, North Korea, Syria, and the Crimea region of Ukraine
• High-Risk Jurisdictions: We may restrict services to users in jurisdictions that are identified by the Financial Action Task Force (FATF) or other regulatory bodies as having high risks for money laundering or terrorist financing
• Jurisdictions with Prohibitive Crypto Regulations: We may restrict services to users in jurisdictions where cryptocurrency or digital asset transactions are prohibited or heavily restricted by local law

Note: This list is subject to change as sanctions programs and regulations evolve. We update our jurisdictional restrictions regularly to reflect changes in law and policy. If you are unsure whether our services are available in your jurisdiction, please contact us before attempting to use our platform.

VPN and Location Circumvention:

You may not use a virtual private network (VPN), proxy, or other method to circumvent our jurisdictional restrictions. If we determine that you are accessing our platform from a restricted jurisdiction or attempting to circumvent our restrictions, we will immediately suspend or terminate your account.

Account Restrictions:

Even if you are located in a permitted jurisdiction, we may impose additional restrictions or requirements on your account if:

• You are identified as a high-risk user based on our risk assessment procedures
• You have connections to restricted jurisdictions or sanctioned entities
• We determine that providing services to you would create unacceptable legal or regulatory risk

We reserve the right to restrict or terminate accounts from any jurisdiction at any time if we determine that providing services would violate applicable law or create unacceptable risk.

Data Retention and Legal Bases

We retain identity verification information and KYC/KYB data for extended periods to comply with legal requirements and for legitimate business purposes.

Retention Periods

U.S. Legal Requirements: Under the Bank Secrecy Act and FinCEN regulations, we are required to retain certain records for at least 5 years after an account is closed or a relationship is terminated. This includes:

• Identity verification records
• Transaction records
• Correspondence and communications
• Suspicious activity reports (if applicable)

Extended Retention: We may retain identity verification information for longer than 5 years if:

• You have an active account or ongoing relationship with us
• We have an ongoing legal obligation (e.g., pending litigation, regulatory investigation)
• We need the information to prevent fraud or ensure compliance

Legal Bases for Processing

We process your identity verification information based on the following legal bases:

• Legal Obligation: We are required by law to collect and verify user identities under the Bank Secrecy Act, FinCEN regulations, and other applicable laws
• Legitimate Interest: We have a legitimate interest in preventing fraud, maintaining platform security, and protecting our users and business
• Contract Performance: Identity verification is necessary to provide you with our services and perform our contractual obligations
• Compliance with Legal Obligations: Processing your information is necessary to comply with sanctions laws, anti-money laundering laws, and other legal requirements

For users in the European Economic Area (EEA) or United Kingdom, our processing of your identity verification information is primarily based on legal obligation and legitimate interest. For more information about your data protection rights, please see our Privacy Policy.

Data Sharing with Regulatory Authorities

We may be required to share your identity verification information with regulatory authorities in certain circumstances:

• Suspicious Activity Reports (SARs): If we detect suspicious activity, we may be required to file a SAR with FinCEN, which may include your identity information
• Regulatory Requests: Regulatory authorities may request information about our users as part of investigations or examinations
• Law Enforcement Requests: We may provide information to law enforcement agencies in response to valid legal requests (e.g., subpoenas, court orders)

We share information with regulatory and law enforcement authorities only when required by law or when we have a good faith belief that sharing is necessary to comply with legal obligations or prevent illegal activity.

Your Rights and Choices

While we are required by law to collect and retain certain identity verification information, you have rights regarding how we handle your personal information.

Access and Correction:

You have the right to access the personal information we hold about you and to request corrections if the information is inaccurate. To exercise these rights, please contact us using the information provided below. However, please note that we may not be able to modify certain information (such as identity verification records) if doing so would violate our legal obligations or if the information was provided to us by a third-party verification provider.

Data Portability:

In some jurisdictions, you may have the right to receive your personal information in a structured, machine-readable format. However, we may not be able to provide all identity verification information if it would violate our legal obligations or compromise security.

Account Closure:

You may request to close your account at any time. However, we will retain your identity verification information for the retention periods described above to comply with legal requirements.

Complaints:

If you have concerns about how we handle your identity verification information, you may:

• Contact us directly (see "Contact Information" below)
• File a complaint with your local data protection authority (if you are in the EEA or UK)
• Contact FinCEN or other relevant regulatory authorities if you believe we have violated applicable laws

For more information about your data protection rights, please see our Privacy Policy.

Contact Information

For questions about this KYC / AML & Sanctions Compliance Overview, identity verification, or compliance matters:

For more information about how we collect, use, and protect your personal information, please see our Privacy Policy. For information about your account access or platform use, please see our Terms of Service.

For more contact options and additional ways to reach us, please visit our Contact page.