Jupiter Meta Labs Foundation & JMDT Blockchain/Web3/Utility Tokens
Document Version: 1.0 Effective Date: [Date] Last
Reviewed: [Date] Next Review Date: [Date + 12 months]
1. PURPOSE AND SCOPE
1.1 Purpose
This Anti-Money Laundering (AML) Policy establishes the framework for the Foundation and its JMDT tokens to
prevent illicit activity, ensure AML/CFT compliance, protect the ecosystem, and establish risk/reporting
procedures.
1.2 Scope
- All JMDT token transactions and interactions
- All users, partners, third parties engaging with JMDT tokens
- All Foundation staff and representatives
- All blockchain interactions, including external wallets
1.3 Regulatory Framework
- International AML/CFT standards and recommendations (e.g., FATF)
2. CDD AND KYC REQUIREMENTS
Immediate Action Required: Implement mandatory, risk-based KYC.
2.1.1 Tier 1 - Basic KYC
- Legal name, date of birth, nationality/residence, email/phone, source of funds
2.1.2 Tier 2 - Enhanced KYC
Triggers: ≥ $600 single or ≥ $2,400 monthly
- Government ID, address proof, relevant tax identifier, source of wealth
2.1.3 Tier 3 - Enhanced Due Diligence (EDD)
Triggers: PEPs; high-risk jurisdictions; ≥ $12,000; suspicious patterns
2.2 KYC Verification Process
- Secure collection; encrypted uploads
- Automated + manual verification
- Approval 24–72 hours (standard)
- Records retained ≥ 10 years
2.3 Ongoing Monitoring
- Annual refresh; re-verify on suspicion; update PEP status
3. TRANSACTION MONITORING AND LIMITS
3.1 Limits
All limits shown in USD.
| User Tier |
Daily (USD) |
Monthly (USD) |
Annual (USD) |
| Unverified |
$120 |
$300 |
$1,200 |
| Basic KYC |
$2,400 |
$12,000 |
$60,000 |
| Enhanced KYC |
$12,000 |
$60,000 |
$600,000 |
| Institutional |
Custom |
Custom |
Custom |
3.2 Automated Monitoring
- Velocity, thresholds, patterns, geography, wallet risk
- Detect rapid trades, new-wallet transfers, mixers, unusual geo, profile mismatch
- Clustering, chain analysis, DeFi monitoring, cross-chain tracking
4. SANCTIONS SCREENING AND COMPLIANCE
4.1 Sanctions Lists
- Applicable sanctions lists (e.g., OFAC, UN, EU)
4.1.2 Screening Process
- Real-time onboarding screening
- Pre-transaction screening for high-value transfers
- Weekly batch screening; wallet address screening
4.2 Geographic Restrictions
- Prohibited: Sanctioned/high-risk jurisdictions
- EDD: Strategic-deficient, tax havens, high corruption
5. RISK ASSESSMENT AND SCORING
- Factors (weights): Geographic 25%, Customer 30%, Product 20%, Transaction 25%
- Categories: Low (0–30), Medium (31–70), High (71–100)
- Reviews: Onboarding/annual; quarterly; annual
6. RECORD KEEPING AND DATA MANAGEMENT
- Customer: KYC, transactions, risk, comms, SARs
- Blockchain: Logs, wallet associations, smart contracts, cross-chain
- Security/Privacy: AES-256/TLS 1.3, RBAC/audit, retention automation, applicable privacy laws
7. SUSPICIOUS ACTIVITY REPORTING
- Process: automated/manually identified → review → investigation → decision
- Timelines: 24h review; 72h investigation; 5-day internal SAR; regulatory per law
- Regulatory registration and reporting as required by applicable law
8. EXTERNAL WALLETS, DEFI, SMART CONTRACTS
- Approved wallets, assessments, standards, user education
- Prohibit mixers/privacy coins; restrict anonymous DeFi; enhanced monitoring bridges/DEX
- Code audits, multi-sign governance, embedded controls, circuit breakers
9. TRAINING AND GOVERNANCE
- Training: onboarding/annual/specialized/update
- Governance: AML Officer (board reporting), AML Committee cadence
10. MONITORING AND REVIEW
- Annual internal audit; quarterly tests; daily alert review; exception reports
- External audits; regulatory exams; tech/pen tests; continuous improvement
11. IMMEDIATE ACTION ITEMS
Priority 1/2/3 within 30/60/90 days as specified above.
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