AML/KYC & COMPLIANCE POLICY

Last Updated: August 24, 2026

This AML/KYC & Compliance Policy describes the identity-verification, anti-money laundering, sanctions-screening, fraud-prevention, cryptocurrency risk-screening, and related compliance practices that AmzHero may apply in connection with transactions.
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AmzHero is currently operated independently by an individual.

AmzHero seeks to reduce the risk that its services are used in connection with fraud, money laundering, terrorist financing, sanctions violations, stolen assets, unlawful activity, or other unacceptable conduct.

The level of verification and compliance review may differ between transactions depending on the circumstances and identified risk.

This Policy does not mean that AmzHero is a bank, licensed financial institution, regulated payment institution, regulated escrow agent, or statutory financial-monitoring entity unless expressly stated otherwise.

01 — RISK-BASED APPROACH
AmzHero applies a risk-based approach when reviewing transactions.
Not every user or transaction is necessarily subject to the same level of verification.
The level of review may depend on factors including:
— transaction amount
— transaction type
— payment method
— currency
— cryptocurrency involvement
— jurisdiction of the parties
— location of funds
— Source of Funds
— transaction complexity
— nature of the goods, services, business, digital assets, or other transaction subject matter
— information provided by the parties
— counterparty risk
— sanctions exposure
— fraud indicators
— blockchain risk indicators
— unusual transaction behavior
— inconsistencies in information
— third-party payment involvement
— other circumstances relevant to legal, security, fraud, payment, or compliance risk

AmzHero may apply additional verification where a transaction presents elevated or unusual risk.

02 — KYC VERIFICATION
AmzHero may request Know Your Customer (“KYC”) information where reasonably necessary.
Depending on the transaction, users may be asked to provide:
— full legal name
— date of birth
— nationality
— country of residence
— residential address
— telephone number
— email address
— government-issued identification
— passport
— national identity card
— proof of address
— photograph or verification image— information regarding occupation or business activity— additional information reasonably required to confirm identity

AmzHero does not necessarily request all of this information for every transaction.
The scope of verification depends on the circumstances and risk associated with the relevant transaction.

03 — BUSINESS AND CORPORATE VERIFICATION
Where a transaction involves a company, business, organization, or person acting on behalf of another entity, AmzHero may request information including:
— legal business name
— registration information
— jurisdiction of incorporation or registration
— registered address
— business address
— company registration documents
— ownership information
— beneficial ownership information
— names of directors or authorized representatives
— evidence of authority to act for the organization
— business website or online presence
— description of business activities
— contracts, invoices, or other transaction-related documentation

AmzHero may request additional information where ownership, control, or authority cannot reasonably be established.

04 — BENEFICIAL OWNERSHIP
Where reasonably appropriate, AmzHero may request information regarding individuals who ultimately own, control, or benefit from a legal entity or transaction.
This may include:
— identity of beneficial owners
— ownership percentages
— control structure
— supporting corporate documentation
— identification documents
— information regarding persons acting on behalf of another person or entityAmzHero may delay or decline a transaction if beneficial ownership cannot reasonably be understood or verified where such verification is considered necessary.

05 — SOURCE OF FUNDS
AmzHero may request Source of Funds (“SoF”) information where reasonably necessary to understand the origin of money or digital assets used in a transaction.
Depending on the circumstances, supporting information may include:
— bank statements
— payment records
— salary or employment income
— business income
— proceeds from the sale of assets
— investment income
— cryptocurrency transaction history
— cryptocurrency exchange records
— invoices
— contracts
— loan documentation
— evidence of previous transactions
— other information reasonably demonstrating the origin of funds

AmzHero may request additional clarification if the origin of funds is unclear, inconsistent, unexplained, or associated with elevated risk.

06 — SOURCE OF WEALTH
For higher-risk, unusually large, complex, or otherwise appropriate transactions, AmzHero may request Source of Wealth (“SoW”) information.

Source of Wealth generally refers to how a person accumulated their overall wealth or assets.

Relevant information may include:
— business ownership
— employment history
— investment activity
— sale of property or businesses
— inheritance
— investment portfolios
— cryptocurrency holdings
— other legitimate sources of wealth

Source of Wealth information is not necessarily required for ordinary transactions and may be requested only where reasonably appropriate.

07 — AML SCREENING
AmzHero may conduct or arrange anti-money laundering screening in connection with a transaction.
AML review may include:
— review of transaction information
— review of identity information
— Source of Funds assessment
— review of payment activity
— cryptocurrency wallet screening
— blockchain analytics
— sanctions screening
— fraud indicators
— publicly available information
— information provided by third-party compliance services

AmzHero may request explanations, supporting documents, or additional verification where available information raises reasonable concerns.

08 — SANCTIONS SCREENING
AmzHero may screen transaction participants, entities, wallet addresses, payments, or other relevant information against applicable sanctions information.
Depending on the transaction and jurisdiction, screening may consider sanctions administered by relevant authorities, including where applicable:
— Ukrainian sanctions authorities
— OFAC
— European Union sanctions authorities
— United Kingdom sanctions authorities
— United Nations sanctions
— other relevant sanctions authorities or databases

The inclusion of a sanctions authority in this Policy does not mean that every sanctions regime applies to every AmzHero transaction.

AmzHero may decline, delay, suspend, or restrict a transaction where sanctions concerns cannot reasonably be resolved.

09 — POLITICALLY EXPOSED PERSONS
Where reasonably appropriate, AmzHero may review whether a transaction participant is a politically exposed person (“PEP”), a family member of a PEP, or a person known to be closely associated with a PEP.PEP status does not by itself mean that a person is involved in unlawful activity.

However, additional information or enhanced review may be requested where reasonably appropriate because of increased corruption, financial-crime, compliance, or reputational risk.

10 — CRYPTOCURRENCY AML SCREENING
Transactions involving cryptocurrency may be subject to additional blockchain-related review.
AmzHero may review:
— wallet addresses
— transaction hashes
— blockchain transaction history
— source wallets
— destination wallets
— exposure to identified high-risk services
— transaction patterns
— risk indicators produced by blockchain analytics providers
— links to sanctioned or suspicious addresses
— links to stolen or illicit funds where identified
— other blockchain information reasonably relevant to transaction risk

Third-party blockchain analytics tools may be used to assist with this review.

11 — HIGH-RISK CRYPTOCURRENCY ACTIVITY
AmzHero may decline, suspend, delay, restrict, or request additional information regarding cryptocurrency associated with elevated risk indicators.
Such indicators may include potential connections to:
— sanctioned wallet addresses
— stolen cryptocurrency
— ransomware
— fraud
— scams
— darknet markets
— terrorist financing
— money laundering
— hacked platforms
— unauthorized account access
— other identified criminal activity
— services or transaction patterns presenting unacceptable risk

A blockchain risk indicator does not necessarily prove unlawful activity.
AmzHero may request additional information before determining whether a transaction can proceed.

12 — NO GUARANTEE FROM SCREENING
AML, KYC, sanctions, blockchain, fraud, or other compliance screening cannot guarantee that a person, wallet, transaction, business, asset, payment, or Source of Funds is legitimate or completely free from unlawful activity.

Compliance tools may rely on:
— third-party databases
— public records
— information supplied by users
— blockchain data
— automated risk indicators
— external service providersSuch information may be incomplete, delayed, inaccurate, unavailable, or subject to interpretation.

A successful compliance review does not constitute a guarantee, certification, endorsement, recommendation, or representation by AmzHero regarding the honesty, reliability, legality, solvency, or future conduct of a transaction participant.

Users remain responsible for their own due diligence.

13 — ENHANCED REVIEW
AmzHero may apply enhanced review where a transaction presents elevated or unusual risk.
Additional review may be appropriate because of factors including:
— unusually large transaction value
— unusual payment structure
— multiple unrelated payment sources
— complex ownership structures
— high-risk jurisdictions
— inconsistent information
— unusual cryptocurrency activity
— unexplained third-party payments
— sanctions concerns
— identity concerns
— fraud indicators
— unclear Source of Funds
— unusually complex transaction structure
— attempts to avoid reasonable verification
— other relevant risk indicators

Enhanced review may require additional documentation, explanations, verification, or transaction conditions.

14 — THIRD-PARTY PAYMENTS
Payments made by a person or entity other than the identified transaction participant may require additional review.
AmzHero may request information regarding:
— identity of the third-party payer
— relationship between the payer and transaction participant
— reason for the third-party payment
— Source of Funds
— authorization for the payment
— supporting transaction documentationAmzHero may decline to accept or continue processing a third-party payment where the relationship, purpose, authority, or Source of Funds cannot reasonably be understood.

15 — SUSPICIOUS OR INCONSISTENT ACTIVITY
AmzHero may request further information or take additional precautions if transaction activity appears unusual, suspicious, or inconsistent.
Examples may include:
— information that conflicts with previously provided information
— reluctance to explain the purpose of a transaction
— unexplained changes to payment instructions
— use of multiple unrelated accounts or wallets
— unusual urgency without reasonable explanation
— attempts to avoid KYC or compliance review
— unexplained Source of Funds
— transactions inconsistent with their stated purpose
— suspicious or inconsistent documentation
— evidence of impersonation
— suspected account compromise
— indications of fraud
— attempts to conceal relevant transaction participants
— other circumstances creating reasonable concern

The presence of one indicator does not necessarily establish unlawful activity.

16 — RIGHT TO REQUEST ADDITIONAL INFORMATION
AmzHero may request additional information or documentation at any stage of a transaction where reasonably necessary for:
— identity verification
— transaction verification
— AML review
— sanctions review
— fraud prevention
— Source of Funds verification
— Source of Wealth verification
— payment verification
— beneficial ownership verification
— dispute handling
— security
— legal or compliance purposes

The transaction may remain pending while requested information is reviewed.

17 — FAILURE TO PROVIDE INFORMATION
Users are expected to provide information reasonably requested in connection with compliance, security, fraud-prevention, or transaction reviews.
If requested information is not provided, is materially incomplete, appears false, is inconsistent, or cannot reasonably be verified, AmzHero may:
— delay the transaction
— suspend processing
— restrict release of funds where reasonably and legally possible
— refuse a payment method
— request an alternative payment method
— decline the transaction
— cancel or discontinue the transaction
— coordinate a refund where appropriate and legally possible
— cease providing services to the relevant participant

AmzHero is not required to proceed with a transaction where identified compliance, fraud, security, or legal concerns cannot reasonably be resolved.

18 — RIGHT TO DECLINE OR SUSPEND TRANSACTIONS
AmzHero may, to the extent permitted by applicable law and transaction conditions, decline, delay, suspend, restrict, or discontinue a transaction where reasonably necessary because of:
— suspected fraud
— suspected money laundering
— suspected terrorist financing
— sanctions concerns
— stolen assets
— suspicious cryptocurrency activity
— identity concerns
— beneficial ownership concerns
— Source of Funds concerns
— unlawful activity
— payment problems
— security concerns
— misleading or inconsistent information
— refusal to provide reasonably requested information
— unacceptable compliance risk
— unacceptable fraud or financial-crime risk
— legal or regulatory concerns
— reputational risk
— other material risk

AmzHero may not always be able to provide detailed information regarding the reason for a compliance-related restriction where disclosure would be inappropriate, legally restricted, or could compromise security, fraud-prevention, or compliance procedures.

19 — PROHIBITED ACTIVITY
AmzHero must not knowingly be used to facilitate transactions involving:
— money laundering
— terrorist financing
— proceeds of crime
— fraud or attempted fraud
— stolen property, funds, accounts, or digital assets
— sanctioned persons, entities, jurisdictions, assets, or prohibited activities where applicable
— unlawful circumvention of sanctions or other legal restrictions
— knowingly false identification
— forged, altered, or materially misleading documentation
— unauthorized access to accounts, wallets, systems, platforms, or data
— concealment of beneficial ownership where such information is reasonably required
— unexplained or suspicious third-party payments
— funds whose origin cannot reasonably be established where Source of Funds information is requested
— attempts to avoid reasonable AML, KYC, sanctions, fraud-prevention, or other compliance procedures
— other activity prohibited by applicable law

AmzHero may also decline transactions that create unacceptable compliance, security, legal, fraud, financial-crime, payment, or reputational risk even where specific unlawful conduct has not been established.

Transactions may also be declined where they fall within categories prohibited under the AmzHero Terms of Use or where AmzHero is unable to reasonably understand, verify, or support the transaction.

20 — USER OBLIGATIONS
Users must:
— provide truthful and accurate information
— avoid knowingly providing false or misleading documents
— cooperate with reasonable verification requests
— provide Source of Funds information where reasonably requested
— provide beneficial ownership information where reasonably requested
— notify AmzHero of material changes affecting the transaction
— use only payment methods, accounts, and wallets they are authorized to use
— avoid using AmzHero for unlawful purposes
— comply with applicable transaction conditions
— comply with applicable lawUsers remain responsible for the accuracy, completeness, and legality of information and documentation they provide.

21 — DATA AND DOCUMENT RETENTION
Information provided for AML, KYC, sanctions, fraud-prevention, or compliance purposes may be retained where reasonably necessary for:
— transaction administration
— fraud prevention
— risk management
— dispute handling
— maintaining transaction history
— compliance purposes
— responding to lawful authority requests
— establishing, exercising, or defending legal rights

At the current stage of AmzHero’s operations, some compliance information may remain within email, Telegram, WhatsApp, website submissions, or other communication channels used to administer transactions.

Retention and processing of personal information are further described in the AmzHero Privacy Policy.

22 — PRIVACY OF KYC AND COMPLIANCE INFORMATION
Identification documents and other compliance information may contain sensitive personal information.
AmzHero seeks to avoid requesting information that is not reasonably necessary for the relevant purpose.
Information may be shared where reasonably necessary with:
— AML or compliance providers
— identity-verification providers
— blockchain analytics providers
— banks
— payment providers
— professional advisers
— competent authorities where legally required or permitted
— other service providers reasonably necessary for the relevant review

Third-party providers may process information according to their own privacy policies, systems, security practices, and legal obligations.

23 — LAW ENFORCEMENT AND REGULATORY COOPERATION
AmzHero cooperates with authorized law enforcement agencies, regulators, courts, and other competent authorities in accordance with applicable law.Information reasonably available to AmzHero may be preserved or disclosed where legally required or otherwise lawfully permitted.

Official requests may be reviewed for:
— authenticity
— legal authority
— validity
— scope
— relevance

AmzHero cannot provide information that is not reasonably available to it.
Further information is available on the Law Enforcement & Regulatory Requests page.

24 — REPORTING AND LEGAL OBLIGATIONS
Where AmzHero becomes legally obligated to preserve information, provide information, restrict a transaction, or take another action, AmzHero may comply with the applicable legal requirement.

Nothing in this Policy should be interpreted as a statement that AmzHero is a statutory reporting entity, bank, financial institution, licensed payment provider, regulated escrow agent, or subject of primary financial monitoring unless such status actually applies under applicable law.

AmzHero may nevertheless apply voluntary risk-management and compliance procedures designed to reduce exposure to fraud, money laundering, sanctions violations, stolen assets, and other unlawful activity.

25 — THIRD-PARTY COMPLIANCE SERVICES
AmzHero may use independent third-party providers for compliance-related purposes.
These may include providers of:
— identity verification
— AML screening
— sanctions screening
— blockchain analytics
— wallet risk assessment
— fraud detection
— payment verification
— public-record information
— other compliance or risk-management servicesAmzHero does not control the databases, algorithms, infrastructure, security, availability, or independent decisions of third-party providers.

Information provided by such services may be considered together with other information reasonably available to AmzHero.

26 — FALSE POSITIVES AND ERRORS
Compliance screening systems are not perfect.
A person, payment, wallet, transaction, company, or asset may be incorrectly identified as presenting elevated risk.
Where reasonably possible, AmzHero may request additional information or conduct further review before making a decision.
However, AmzHero is not required to accept or continue a transaction where unresolved risk remains unacceptable.

27 — NO RIGHT TO TRANSACTION APPROVAL
Submission of identification documents, completion of KYC, successful AML screening, sanctions screening, Source of Funds review, or any other compliance procedure does not create a right to use AmzHero or require AmzHero to accept or complete a transaction.
AmzHero may decline a transaction where reasonably necessary because of:
— compliance concerns
— security concerns
— fraud risk
— payment risk
— operational limitations
— legal concerns
— transaction complexity
— inability to reasonably verify relevant information
— inability to reasonably understand the transaction
— other legitimate risk considerationsAmzHero is not required to accept or continue a transaction merely because the transaction is not known to be unlawful.

28 — CHANGES TO THIS POLICY
AmzHero may update this AML/KYC & Compliance Policy from time to time to reflect changes in:
— services
— transaction procedures
— payment methods
— cryptocurrency practices
— risk-management procedures
— compliance providers
— applicable law
— sanctions requirements
— technology
— operational practices

The current version will be published on the AmzHero website with an updated “Last Updated” date.29 — CONTACT

Questions regarding this AML/KYC & Compliance Policy may be submitted through the official AmzHero contact channels published on the website.

Users who receive a request for additional compliance information should respond through the communication channel confirmed for the relevant transaction.

Authorized law enforcement agencies and regulatory authorities should use the procedure described on the Law Enforcement & Regulatory Requests page.

IMPORTANT COMPLIANCE NOTICE

AmzHero may request KYC, AML, Source of Funds, Source of Wealth, beneficial ownership, sanctions, cryptocurrency wallet, payment, or other compliance information where reasonably appropriate based on the circumstances of a transaction.

The level of verification may differ between transactions.

Completion of a compliance review does not constitute a guarantee that a buyer, seller, counterparty, wallet, payment, business, digital asset, Source of Funds, or transaction is legitimate, reliable, lawful, or free from risk.

Each transaction participant remains responsible for their own conduct, representations, compliance with applicable law, and due diligence.

AmzHero may decline, delay, suspend, restrict, or discontinue a transaction where reasonably necessary because of unresolved fraud, AML, sanctions, security, payment, legal, compliance, or other material risk concerns.

AmzHero is not required to accept or continue a transaction merely because unlawful activity has not been established.

This Policy describes AmzHero’s transaction risk-management and compliance practices.

It does not by itself represent that AmzHero is a bank, licensed financial institution, regulated payment institution, regulated escrow agent, or statutory financial-monitoring entity.