Know Your Customer (KYC), Anti-Money Laundering (AML) & Know Your Business (KYB) Policy

(Incorporated by reference into the Fisheez Terms of Service and SmartShell Escrow Agreement.)

Purpose & Scope

This policy defines how Fisheez PBC verifies user and business identities, prevents illicit activity, and maintains compliance with applicable anti-money-laundering (AML), sanctions, and counter-terrorism financing (CTF) laws.

It applies to all users and entities — including Buyers, Sellers, Service Providers, Promoters, Peacemakers, and Marketplace Partners — who transact, earn, or receive value through the Fisheez Platform or SmartShell contracts.

Fisheez operates strictly as a non-custodial marketplace facilitator, not a financial institution or money transmitter.

All payments occur directly between blockchain wallets via SmartShell contracts. Fisheez does not hold or redirect user funds.

A. Identity Verification (KYC)

1. When Verification Is Required

   • Creating or purchasing a Shorefront NFT (seller activation).
   • Receiving or withdrawing funds above platform thresholds.
   • Acting as a Peacemaker or other governance participant.
   • Triggering AML or sanctions screening events (e.g., cross-border payments).

2. Verification Methods

   • Performed through encrypted, privacy-preserving third-party compliance tools.

   • May include:

     • government-issued ID;

     • biometric or facial confirmation;

     • address and date-of-birth validation;

     • business or tax documentation when relevant.

3. Record Handling

   • Fisheez stores only verification results (pass/fail) and minimal metadata.
   • Sensitive documents remain encrypted and processed under CCPA/GDPR standards.

B. Anti-Money Laundering (AML) & Sanctions Compliance

1. Prohibited Use

   Users may not engage in:

   • money laundering, terrorism financing, or sanctions evasion;
   • fraud, tax evasion, or deceptive fundraising;
   • sale or laundering of stolen assets or digital contraband.

2. Screening & Monitoring

   • Transactions may be screened against OFAC, UN, and EU sanctions lists.
   • Fisheez may restrict or terminate flagged accounts.
   • Additional verification may be required for high-risk or large-volume activity.

3. Reporting

   • Although Fisheez is not a money transmitter, it may submit suspicious-activity notices or cooperate with law enforcement when legally required.
   • Users consent to such cooperation by using the platform.

C. Peacemaker & Governance Integrity

• Peacemakers and dispute participants must complete verified KYC before voting or moderating.
• Conflict checks ensure no related or duplicate identities participate in the same case.
• This maintains transparency and trust in community-based dispute resolution.

D. Data Privacy & Retention

1. Personal data is encrypted and handled under the Fisheez Privacy Policy.
2. Verification data is retained only as long as required by law or regulatory audit needs.
3. Users may request deletion once retention requirements expire and no active transactions remain.

E. Non-Custodial Limitation

• Fisheez never holds user funds or fiat currency.
• Compliance procedures exist solely to prevent fraud and ensure lawful platform use.
• Users retain full control of their wallets and private keys at all times.

F. Enforcement

1. Accounts may be suspended or terminated for:
   • falsified or unverifiable information;
   • attempts to evade screening;
   • confirmed links to illicit activity; or
   • refusal to cooperate with lawful compliance reviews.
2. Verified violations may be reported to regulators or law enforcement.
3. Enforcement actions are taken in good faith to maintain platform integrity.

G. Know Your Business (KYB) Verification

1. Applicability

   KYB applies to any business entity operating on Fisheez — including LLCs, corporations, partnerships, or nonprofits — that:

   • opens or manages a Shorefront on behalf of a company;
   • conducts recurring or high-volume transactions; or
   • receives or distributes funds for third parties.

2. Information Required

   Fisheez may collect and verify:

   • Legal business name, registration number, and address.
   • Employer Identification Number (EIN) or tax ID.
   • Articles of incorporation, business license, or equivalent formation proof.
   • Ownership and control structure (beneficial owners ≥25%).
   • Identity of authorized signers or representatives.
   • Operational domain, social presence, or other public verification data.

3. Beneficial Ownership Disclosure

   • Businesses must disclose ultimate beneficial owners (UBOs) under the Corporate Transparency Act (31 U.S.C. §5336).
   • Fisheez screens for shell companies, sanctioned entities, and high-risk jurisdictions.

4. Ongoing Review

   • KYB data may be re-verified periodically or when risk indicators arise.
   • Accounts that fail to update required documentation may be suspended.

5. Cross-Verification with KYC

   • Authorized representatives must complete individual KYC checks.
   • This ensures both the entity and its signers meet compliance standards.

6. Data Retention & Privacy

   • KYB records are encrypted and stored according to applicable privacy laws.
   • Only minimal verification outcomes are retained for audit purposes.

H. Legal References

• Bank Secrecy Act (31 U.S.C. §5311 et seq.)
• USA PATRIOT Act Title III
• Corporate Transparency Act (31 U.S.C. §5336)
• FinCEN 2019 Guidance on Convertible Virtual Currencies
• OFAC Sanctions Regulations (31 C.F.R. Parts 500–599)
• UETA & E-Sign Act
• GDPR / CCPA