Compliance Document

Anti-Money Laundering Policy

Last Updated: May 29, 2026 · Policy Version: 4.2

FinCEN Registration #: 31000272948819 · BSA/AML Officer: Chief Compliance Officer · Program Review: Annual (last reviewed May 29, 2026)

Ironclad Capital LLC ("Ironclad Capital", "the Firm") is committed to the highest standards of Anti-Money Laundering (AML) compliance. This policy establishes our framework for detecting, preventing, and reporting money laundering, terrorist financing, and other financial crimes in accordance with the Bank Secrecy Act (BSA), the USA PATRIOT Act, FinCEN regulations, FINRA Rule 3310, and all applicable federal and state laws.

1. Policy Statement and Scope

Ironclad Capital LLC maintains a comprehensive, risk-based AML/BSA compliance program designed to prevent the Firm from being used as a conduit for money laundering, terrorist financing, fraud, sanctions violations, or any other financial crime.

This policy applies to:

All employees, contractors, and agents of Ironclad Capital LLC
All clients and prospective clients seeking investment advisory services
All financial transactions processed through our platform, including cryptocurrency deposits, withdrawals, and inter-account transfers
All jurisdictions in which we operate or accept clients

Non-compliance with this policy may result in disciplinary action, up to and including termination of employment, and may be reported to relevant law enforcement authorities.

2. Regulatory Framework

Our AML program is designed to comply with the following laws and regulations:

Bank Secrecy Act (BSA), 31 U.S.C. §§ 5311–5336 — Primary federal AML legislation
USA PATRIOT Act (2001) — Enhanced customer identification and due diligence requirements
FinCEN Regulations (31 C.F.R. Parts 1010–1029) — BSA implementing regulations
FINRA Rule 3310 — AML compliance program requirements for FINRA members
OFAC Regulations — Office of Foreign Assets Control sanctions compliance
Investment Advisers Act of 1940 — SEC regulatory requirements
Anti-Money Laundering Act of 2020 — Enhanced beneficial ownership and AML requirements
Corporate Transparency Act (2024) — Beneficial ownership reporting to FinCEN

3. AML Program Components

Our AML program consists of five core components as required by FINRA Rule 3310 and FinCEN regulations:

3.1 Internal Policies, Procedures, and Controls

We have established written policies and procedures that:

Identify and assess money laundering risks specific to our business
Establish clear controls to mitigate identified risks
Define escalation procedures for suspicious activity
Set forth record-keeping requirements and retention schedules
Address cryptocurrency-specific AML risks including blockchain analysis requirements

3.2 Designated AML Compliance Officer

Our Chief Compliance Officer (CCO) serves as the designated AML Officer with responsibility for:

Day-to-day implementation and oversight of the AML program
Filing Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs)
Coordinating with law enforcement and regulatory authorities
Ensuring program updates reflect regulatory changes
Reporting AML program status to senior management and the Board

3.3 Ongoing Employee Training

All relevant personnel receive AML training upon hire and annually thereafter, covering:

Recognition of suspicious activity and red flags
Customer identification and due diligence procedures
SAR and CTR filing obligations and confidentiality requirements
OFAC sanctions screening and compliance
Cryptocurrency-specific money laundering typologies
Consequences of non-compliance

3.4 Independent Testing

Our AML program undergoes independent testing (audit) at least annually by qualified personnel who are independent of the compliance function. The audit assesses the adequacy and effectiveness of our AML controls and reports findings to senior management.

3.5 Customer Due Diligence

See Section 5 for detailed CDD/KYC procedures.

4. Risk Assessment

Ironclad Capital conducts a formal AML risk assessment at least annually to identify, assess, and prioritize money laundering and terrorist financing risks. Risk factors assessed include:

4.1 Client Risk Factors

Geographic location (domestic vs. international; FATF high-risk jurisdictions)
Client type (individual, corporate, trust, politically exposed person)
Source of funds and wealth
Investment amounts and behavioral patterns
PEP (Politically Exposed Person) or sanctions list status

4.2 Product and Service Risk Factors

Cryptocurrency transactions (inherently higher risk due to pseudonymity)
Cross-border fund flows
Investment plan structures and payout mechanisms

4.3 Geographic Risk Factors

We apply enhanced due diligence to clients from FATF-designated high-risk or non-cooperative jurisdictions, OFAC sanctioned countries, and jurisdictions with known AML deficiencies. We do not accept clients from: Iran, North Korea, Syria, Cuba, the Crimea region of Ukraine, Russia (select sectors), Belarus (select sectors), and other OFAC-sanctioned jurisdictions.

5. Customer Identification Program (CIP) and Due Diligence

5.1 Customer Identification Program (CIP)

Pursuant to 31 C.F.R. § 1023.220 and the USA PATRIOT Act, we collect and verify the following information for all clients before opening an account:

For Individual Clients:

Full legal name
Date of birth
Residential street address (no PO boxes)
Social Security Number, ITIN, or passport number for non-U.S. persons
Government-issued photo identification (driver's license, passport, national ID)

For Entity Clients:

Legal entity name and type
Principal place of business address
Employer Identification Number (EIN) or equivalent
Articles of incorporation or equivalent formation documents
Beneficial ownership information (all individuals owning 25%+ of the entity)

5.2 Standard Customer Due Diligence (CDD)

For all clients, we conduct standard CDD which includes:

Identity verification through a combination of documentary and non-documentary methods
Screening against OFAC Specially Designated Nationals (SDN) list and other sanctions lists
Politically Exposed Person (PEP) screening
Adverse media screening
Source of funds verification for deposit amounts exceeding $10,000
Understanding the nature and purpose of the client relationship

5.3 Enhanced Due Diligence (EDD)

EDD is applied to higher-risk clients, including but not limited to:

Politically Exposed Persons (PEPs) and their immediate family members and close associates
Clients from FATF high-risk jurisdictions
Clients with complex ownership structures
Clients making deposits exceeding $50,000 in a single transaction
Clients exhibiting unusual transaction patterns
Non-U.S. financial institutions and their clients

EDD measures include additional identity verification, source of wealth documentation, senior management approval, and more frequent account monitoring.

5.4 Cryptocurrency-Specific Due Diligence

Given the unique risks associated with cryptocurrency transactions, we apply the following additional controls:

Blockchain analytics screening of all incoming cryptocurrency wallet addresses using industry-leading tools
Rejection of funds from wallets identified as high-risk (darknet markets, mixing services, sanctioned entities)
Travel Rule compliance for transfers above applicable thresholds
Enhanced monitoring of cryptocurrency transaction patterns

6. Ongoing Monitoring

We conduct ongoing monitoring of client accounts and transactions to detect suspicious activity, including:

Transaction Monitoring: Automated and manual review of deposits, withdrawals, and account activity for patterns inconsistent with the client's stated profile
Threshold Monitoring: Automated alerts for transactions meeting or approaching reporting thresholds ($10,000 for CTRs)
Pattern Analysis: Review of structuring patterns, rapid movement of funds, and unusual concentration of activity
Periodic Review: Risk-based review of client accounts at defined intervals (high-risk: every 6 months; medium-risk: annually; low-risk: every 3 years)
Sanctions Rescreening: Ongoing screening of client database against updated sanctions lists

7. Suspicious Activity Reporting (SAR)

We are required by the BSA and FINRA rules to file Suspicious Activity Reports (SARs) with FinCEN for transactions that:

Involve $5,000 or more and the Firm knows, suspects, or has reason to suspect involve funds derived from illegal activity
Are designed to evade BSA reporting requirements (structuring)
Lack a lawful purpose or are not the type of transaction in which the client would normally engage
Involve the use of the Firm to facilitate criminal activity

7.1 SAR Process

Any employee who identifies suspicious activity must immediately report it to the AML Officer
The AML Officer reviews the report within 5 business days and makes a filing determination
SARs are filed with FinCEN within 30 calendar days of initial detection (60 days if no suspect is identified)
SARs and supporting documentation are retained for 5 years from the date of filing
Tipping Off Prohibition: The existence or contents of a SAR must not be disclosed to any person involved in the reported activity

8. Currency Transaction Reports (CTR)

We file Currency Transaction Reports (CTRs) with FinCEN for cash transactions (including cryptocurrency) exceeding $10,000 in a single business day. This includes:

Single transactions exceeding $10,000
Multiple transactions by or on behalf of the same person that aggregate to more than $10,000 in a single day (aggregation rule)

CTR exemptions are maintained in accordance with FinCEN regulations for qualified exempt persons. CTRs and supporting documentation are retained for 5 years.

9. OFAC Sanctions Compliance

We screen all clients, beneficial owners, counterparties, and wallet addresses against:

OFAC Specially Designated Nationals and Blocked Persons List (SDN List)
OFAC Sectoral Sanctions Identifications List (SSI List)
OFAC Foreign Sanctions Evaders List (FSE List)
UN Security Council Consolidated Sanctions List
EU Consolidated Sanctions List
HM Treasury (UK) Financial Sanctions List

Any potential match triggers an immediate hold on the account or transaction, escalation to the AML Officer, and if confirmed, blocking and reporting to OFAC within 10 business days.

10. Record Keeping

We maintain the following records in accordance with BSA requirements:

CIP Records: 5 years from account closing
SAR Records: 5 years from filing date
CTR Records: 5 years from filing date
Transaction Records: 5 years from transaction date
OFAC Search Records: 5 years from date of screening
Training Records: 5 years from training date
Audit Reports: 5 years from report date

All records are maintained in secure, encrypted storage and are available for examination by FinCEN, SEC, FINRA, and other authorized regulatory authorities upon request.

11. Prohibited Activities

The following activities are strictly prohibited on our platform:

Structuring transactions to avoid BSA reporting requirements
Transacting with OFAC-sanctioned individuals, entities, or jurisdictions
Using our platform for the purpose of money laundering or terrorist financing
Depositing funds derived from illegal activities
Using cryptocurrency mixing, tumbling, or obfuscation services
Providing false or misleading information during KYC processes
Attempting to circumvent our AML controls through any means

Violations of these prohibitions will result in immediate account termination, asset freezing, filing of a SAR, and referral to law enforcement as appropriate.

12. Whistleblower Protections

Ironclad Capital prohibits retaliation against any employee who in good faith reports suspected violations of our AML policies or who participates in an investigation of such violations. Retaliation against whistleblowers is itself a violation of Firm policy and may constitute a violation of applicable law.

Employees may report AML concerns confidentially through our internal reporting channel or directly to FinCEN, the SEC, or FINRA through their respective whistleblower programs.

13. Program Review and Updates

This AML Policy is reviewed and updated at least annually, or more frequently as needed to reflect:

Changes in applicable laws or regulations
Findings from independent AML program audits
Changes to our business model or client base
Regulatory guidance, examinations, or enforcement actions
Emerging money laundering typologies or new criminal techniques

Material changes to this policy require approval from the Chief Compliance Officer and senior management.

14. Reporting and Contact

AML Compliance Department

Chief Compliance Officer / AML Officer

Ironclad Capital LLC

1 World Trade Center, New York, NY 10007

Email: aml@ironcladcapital.tech

Confidential AML Hotline: +1 (800) 467-6299

FinCEN Registration #: 31000272948819

FINRA CRD #: 3281947

To report suspicious activity to FinCEN: fincen.gov

FINRA AML resources: finra.org/aml