AML Policy


Anti-Money Laundering (AML) Policy

Yanance, Inc. and Yanance USA, Inc.
(collectively, the “Company”)

1. Introduction

Yanance, Inc. and Yanance USA, Inc. are corporations organized under the laws of the State of Oregon. The Company operates an internet-enabled peer-to-peer (“P2P”) marketplace facilitating the purchase and sale of digital assets.

Yanance is registered as a Money Services Business (“MSB”) with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”). This AML Policy establishes the Company’s framework for preventing money laundering, terrorist financing, and other illicit activities, while protecting its users, its business, and the broader digital asset ecosystem.

The Company complies with the Bank Secrecy Act (BSA), applicable FinCEN regulations, guidance, and other relevant laws.

2. Scope

This Policy applies to all Company users, employees, officers, directors, owners, consultants, and agents. Compliance with this Policy is mandatory and a condition of participation on the Yanance platform.

3. Compliance Framework

Yanance has adopted a risk-based AML and Know Your Customer (“KYC”) program designed to reasonably verify the identity of each user and to detect, prevent, and report suspicious activity. Key components include:

3.1 Governance

  • Chief Compliance Officer (CCO): An independent and qualified CCO is appointed to oversee the Company’s compliance program and ensure adherence to laws, regulations, and industry standards.

3.2 Customer Due Diligence

  • Risk-Based KYC: All users undergo Customer Due Diligence (“CDD”) based on risk profiles.

  • Enhanced Due Diligence (EDD): Higher-risk users and transactions are subject to enhanced review and monitoring.

  • Verification Tiers: The Company maintains multiple verification levels, proportionate to user activity and risk.

3.3 Transaction Monitoring & Reporting

  • Suspicious Activity Reporting (SAR): The Company files SARs with FinCEN when it knows, suspects, or has reason to suspect that transactions involve illicit activity, are inconsistent with a user’s known profile, or lack a lawful purpose. The CCO reviews, investigates, documents, and maintains records of all SAR filings.

  • Blockchain Analytics: Monitoring tools, anti-fraud systems, and blockchain analytics are used to detect unusual or suspicious behavior.

3.4 Training & Awareness

  • Employee Training: All relevant personnel receive ongoing training on AML, BSA, and OFAC compliance obligations.

  • Monitoring & Auditing: The Company regularly tests and reviews its compliance program for effectiveness.

3.5 Regulatory Cooperation

  • Yanance cooperates fully with regulators, law enforcement, and other competent authorities in investigations and examinations.

4. Sanctions Compliance

Yanance enforces OFAC sanctions compliance procedures to ensure that prohibited individuals, entities, or jurisdictions do not access its platform.

5. Policy Review

This Policy is reviewed periodically and updated as necessary to reflect changes in applicable laws, regulations, or business operations.