AML/KYC Policy
Maverick Ltd maintains a risk-based financial crime compliance framework for Project ATLAS and its legitimate commercial activities.
1. Purpose and Scope
This policy establishes principles intended to reduce the risk that Project ATLAS services, payment arrangements or business relationships are used for money laundering, terrorist financing, sanctions evasion, fraud or other unlawful activity.
2. Project ATLAS Payment Use
Digital asset payment functionality associated with Project ATLAS is intended for legitimate Maverick Ltd commercial invoices and approved business obligations.
3. Risk-Based Approach
Maverick Ltd may assess business relationships and transactions according to relevant risk factors including customer or counterparty profile, jurisdiction, ownership structure, transaction purpose, payment method, source of funds and other relevant indicators.
4. Individual Identification
Where verification is required, Maverick Ltd may request information such as legal name, date of birth, residential address, nationality, government-issued identification and other supporting information.
5. Business Verification
For companies and other legal entities, information may include legal name, registration details, registered address, business activity, directors, shareholders, ultimate beneficial owners and supporting corporate documentation.
6. Beneficial Ownership
Maverick Ltd may identify and verify individuals who ultimately own or control a legal entity where appropriate to the nature and risk of the business relationship.
7. Sanctions, PEP and Adverse Information
Relevant relationships may be subject to sanctions screening, politically exposed person assessment and review of material adverse information where appropriate.
8. Enhanced Due Diligence
Higher-risk relationships or transactions may require additional information concerning source of funds, source of wealth, business purpose, ownership, transaction rationale or other supporting evidence.
9. Digital Asset Transaction Monitoring
Digital asset transactions may be reviewed using available transaction information, blockchain information, payment-provider controls and other risk indicators.
10. Suspicious Activity
Transactions or relationships presenting material financial crime concerns may be delayed, rejected, suspended, escalated or otherwise handled in accordance with applicable requirements and the company's risk controls.
11. Records
Relevant KYC/KYB, transaction and compliance records may be retained for periods appropriate to applicable legal, contractual, accounting and compliance requirements.
12. Data Protection
Personal information collected for compliance purposes is handled in accordance with the Project ATLAS Privacy Policy and applicable requirements.
13. Governance and Review
Maverick Ltd is responsible for maintaining appropriate oversight of the Project ATLAS compliance framework. Policies and controls may be reviewed and updated as the project, business relationships and applicable requirements evolve.
14. Regulatory Status
This policy describes Maverick Ltd's compliance framework. It does not represent that Maverick Ltd holds a financial-services licence where no such licence is required or held.