KYC/AML Policy

Last Updated: May 8, 2025

HugeOne Ltd. (“HugeOne”, “we”, “us”, or “our”) is committed to ensuring the safety, integrity, and compliance of its platform by implementing robust Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures. These procedures align with international standards, including those set by the Financial Action Task Force (FATF) and the European Union's AML Directives.

1. Policy Purpose

This KYC/AML Policy establishes the procedures and controls implemented by HugeOne to:

Prevent the use of our platform for money laundering, terrorist financing, and other financial crimes.

Identify users, verify their identities, and monitor their activity.

Comply with applicable laws and regulations in all jurisdictions where we operate or offer services.

2. Scope of the Policy

This Policy applies to:

All users accessing HugeOne.io (investors, startups, or token holders).

All transactions, including investments, token staking, fund withdrawals, and NFT/equity allocations.

All payment methods, including cryptocurrencies and fiat gateways (if used).

All services, including wallet interactions, milestone-based funding, and staking participation.

3. User Verification Process (KYC)

HugeOne uses third-party KYC providers to conduct identity verification in accordance with this policy. The following procedures apply:

A. Individual Verification

Users may be required to submit:

Full legal name

Date of birth

Country of residence

Valid government-issued photo ID (passport, driver’s license, national ID)

Proof of address (utility bill, bank statement within last 3 months)

Selfie or biometric confirmation (liveness check)

B. Corporate/Startup Verification

Startups applying to fundraise must submit:

Company name and registration documents

List of directors and beneficial owners

Corporate address and tax identification number

Certificate of incorporation and/or business license

AML/Compliance officer contact (if applicable)

4. Risk-Based Approach (RBA)

HugeOne adopts a Risk-Based Approach to assess users and transactions:

Risk Level Criteria

Low Verified individual from low-risk jurisdiction

Medium Startup entities, moderate volume investors

High Users from high-risk jurisdictions, large transactions, or complex fund flows

Enhanced Due Diligence (EDD) is performed for high-risk users.

5. Prohibited Jurisdictions & Sanctions Screening

We do not provide services to individuals or entities located in or associated with:

Countries sanctioned by the EU, UN, or OFAC (e.g., North Korea, Iran, Syria)

High-risk countries listed by the FATF

Persons on international sanctions or watch lists

All users are screened against:

PEP (Politically Exposed Persons) lists

Sanctions databases (OFAC, EU, UN, UK, etc.)

6. Ongoing Monitoring

Transactions are monitored for unusual activity (e.g., large transfers, high-frequency wallet activity, geographic inconsistencies).

Startups are required to provide milestone updates before each funding disbursement.

Staking and token usage are tracked to detect patterns consistent with layering or fraud.

Suspicious Activity Reports (SARs) may be filed with regulatory authorities where applicable.

7. AML Compliance Officer

We designate a dedicated AML Compliance Officer responsible for:

Overseeing KYC/AML implementation and audits

Updating this policy to reflect changes in regulations

Conducting training and internal reviews

Reporting suspicious activities to authorities if needed

8. Record Keeping

HugeOne securely retains all user KYC and transaction records for a minimum of 5 years, as required by law. This includes:

Identity verification documents

Transaction logs and blockchain receipts

Internal risk assessments and communications

9. User Obligations

Users agree to:

Provide accurate and truthful information during onboarding.

Update their details if there are any changes (e.g., new residence or ID).

Cooperate with KYC re-verification requests.

Refrain from using HugeOne.io for any unlawful purposes.

10. Consequences of Non-Compliance

HugeOne reserves the right to:

Deny access to platform services

Freeze or terminate user accounts

Withhold or reverse transactions

Report suspicious users to authorities

11. Modifications to This Policy

We may revise this KYC/AML Policy periodically. Users will be notified of material changes. Continued use of the platform after policy changes constitutes acceptance.