WireMe LLC — Anti-Money Laundering & Counter-Terrorist Financing (AML/CFT) Policy

Last Updated: February 2026

Email: support@wireme.io | Website: https//www.wireme.io

This disclosure outlines WireMe LLC’s commitment to preventing money laundering, terrorist financing, sanctions evasion, and other illicit activity.

1. Purpose of Disclosure

This Policy describes how WireMe LLC (“WireMe”, “we”, “our”) detects, prevents, and reports suspicious activity across its digital asset and escrow-based services. It applies to all users, brokers, counterparties, and partners interacting with the platform.

2. Commitment & Standards

WireMe maintains a risk-based AML/CFT compliance program aligned with international best practices, including the Financial Action Task Force (FATF) Recommendations. We are committed to maintaining high standards of integrity, transparency, and financial crime prevention.

3. Governance and Oversight

WireMe LLC’s senior management holds responsibility for oversight of the AML/CFT program. A designated Compliance Officer oversees day-to-day operations, monitoring, training, and escalation procedures.

4. Compliance Framework

Our compliance framework includes:

• Know Your Customer (KYC) identity verification;

• Risk-Based Customer Assessment;

• Sanctions and Politically Exposed Person (PEP) screening;

• Blockchain analytics and transaction monitoring;

• Suspicious activity review and lawful reporting;

• Record retention and audit controls.

5. Risk-Based Approach

Customers and transactions are assessed based on jurisdictional, behavioral, transactional, and counterparty risk indicators. Enhanced Due Diligence (EDD) may be required for higher-risk users, including politically exposed persons (PEPs) or high-risk geographies.

6. Sanctions & Screening

WireMe screens users and transactions against global sanctions lists, including but not limited to UN, OFAC (U.S.), EU, and UK sanctions lists. Screening occurs at onboarding and on an ongoing basis. Positive matches may result in account restriction, review, or mandatory reporting to relevant authorities.

7. Customer Verification (KYC & KYB)

Users must complete identity verification before accessing transactional services.

Verification may include:

• Government-issued identification;

• Biometric or liveness checks;

• Proof of residence (where required);

• Source of funds or income documentation;

• For entities: incorporation and beneficial ownership information.

8. Transaction Monitoring & Reporting

WireMe continuously monitors transactions using analytics tools and automated alerts to detect unusual patterns. Where required by applicable law, we may file Suspicious Activity Reports (SARs) or equivalent reports with appropriate authorities. We may be legally prohibited from disclosing such filings.

9. Prohibited Activities

Use of the platform for the following is strictly prohibited:

• Money laundering or terrorist financing;

• Sanctions evasion;

• Fraud, scams, or deceptive schemes;

• Concealment of beneficial ownership;

• Use of anonymity-enhancing tools for unlawful purposes.

10. User Responsibilities

Users and brokers must:

• Provide accurate and updated information;

• Maintain verified accounts;

• Refrain from concealing the source of funds;

• Cooperate with compliance reviews when requested.

11. Data Protection

Personal data collected for AML/CFT purposes is handled in accordance with WireMe’s Privacy Policy and applicable data protection laws. Data is encrypted, access-controlled, and retained as required by law.

12. Cooperation with Law Enforcement

WireMe may cooperate with lawful requests from regulatory, supervisory, or law enforcement authorities in any jurisdiction where legally required.

13. Policy Updates

WireMe may update this Policy to reflect regulatory developments or operational changes. The latest version will be published on our website.