AML Compliance | iCloser — Anti-Money Laundering Policy

Our Commitment

iCloser is committed to maintaining a secure and compliant digital asset infrastructure. To help prevent money laundering, terrorist financing, sanctions violations, and other illicit activity, iCloser applies a risk-based Anti-Money Laundering (AML) and compliance framework to relevant services.

Regulatory Registration

FinCEN Money Services Business (MSB)

Registration Number: 31000311076673

Regulator: Financial Crimes Enforcement Network (FinCEN)

Activities: Dealer in foreign exchange, Money transmitter, Prepaid access seller

🔗 Verify on FinCEN MSB Registry

FinCEN MSB registration is not a recommendation, certification of legitimacy, or endorsement by any government agency.

Self-Custody Wallet Model

iCloser provides self-custody wallet functionality for supported digital asset features.

Users retain control over their wallet credentials and digital assets in self-custody contexts. iCloser does not present this wallet layer as a custodial financial institution relationship and does not custody customer funds.

AML monitoring becomes relevant when users interact with regulated interfaces, partner-supported payment functions, or onboarding flows requiring compliance review.

How Risk Monitoring Works

iCloser may use blockchain analytics, sanctions screening, account review procedures, and transaction monitoring controls to evaluate activity associated with regulated services.

Address and transaction risk analysis
Exposure screening for sanctioned or prohibited parties
Pattern analysis for unusual or suspicious activity
Jurisdictional and eligibility review
Additional verification when risk indicators are identified

Risk-Based Compliance Approach

Depending on the nature of the activity and applicable legal requirements, iCloser or its licensed partners may:

Process activity normally
Request additional verification or documentation
Place a transaction or feature under review
Decline, limit, or restrict access to regulated services
Escalate cases for internal compliance review or legal response

Sanctions and Prohibited Activity

iCloser does not intend to provide regulated services to sanctioned parties, prohibited users, or users in restricted jurisdictions where such services are not permitted.

Availability of the App or website does not mean that all regulated services are available to all users in all jurisdictions.

Suspicious Activity Handling

Where suspicious behavior is identified, iCloser may review activity, restrict access to regulated interfaces, maintain records, or cooperate with licensed partners and authorities when required by law.

KYC Execution Partners

iCloser engages specialized identity verification providers to execute Know Your Customer (KYC) procedures on its behalf. These providers are subject to contractual data protection obligations and applicable regulatory requirements:

Sumsub (sumsub.com) — Executes KYC onboarding for Virtual Account (VA) Financial Infrastructure applications. Sumsub processes government-issued ID documents, liveness verification, and source-of-funds documentation. Sumsub is a globally recognized identity verification provider operating in compliance with FATF guidelines and applicable AML regulations.
Didit (didit.me) — Executes KYC onboarding for Black-Gold Visa access. This is an independent verification flow separate from the VA Financial Infrastructure process. Didit processes identity and liveness verification data in accordance with card network and issuing partner requirements.

FATCA Cross-Reference: For US-person VA account applicants, Tax Identification Number (SSN/EIN) collection occurs as part of the onboarding flow governed by 26 U.S.C. §§ 1471–1474. SSN/EIN data is transmitted to the authorized financial partner or required compliance provider for tax reporting purposes and is not retained in the Sumsub KYC workflow. See our Terms of Service — FATCA Compliance and Privacy Policy for further details.

Cooperation with Licensed Partners

Certain payment, card, account, or settlement services may be offered through licensed financial institutions or authorized partners. Those partners may apply their own onboarding, AML, KYC, transaction review, and service eligibility requirements.

Record Retention and Legal Cooperation

Compliance-related records may be retained in accordance with applicable legal and regulatory requirements. iCloser may respond to lawful requests, legal process, and partner compliance obligations where required.

Contact Information

For AML or compliance-related inquiries:

Email: privacy@icloser.xyz

Address: iCloser Ltd., 1580 N Logan St, Suite 660 #30327, Denver, CO 80203, USA