1. AML / KYC Compliance
ANTI-MONEY LAUNDERING (AML) & KYC COMPLIANCE:
iCloser Ltd. is committed to maintaining robust anti-money laundering (AML) and counter-terrorist financing (CTF) standards under U.S. Bank Secrecy Act (BSA) regulations and FINTRAC guidelines.
- Banking & Card Programs: Customer Identification Programs (CIP), enhanced customer due diligence (CDD), and ongoing transaction monitoring for USD Virtual Accounts and Visa cards are administered in direct coordination with licensed banking partners and authorized card issuers.
- Non-Custodial Infrastructure: For self-custody wallet software and decentralized transactions, iCloser implements protocol-level address screening against illicit finance databases and blacklisted wallets before routing interactions.
2. Non-Custodial Status & Technology Boundaries
NON-CUSTODIAL STATUS & TECHNOLOGY BOUNDARIES:
iCloser provides client-side non-custodial software interfaces. Users generate, store, and manage their own cryptographic private keys.
iCloser Ltd. does not hold, transmit, or custody customer digital assets, nor does it maintain access to user private keys. Compliance obligations that apply specifically to financial custodians or custodial exchanges under FinCEN guidelines do not extend to self-custody software tools where the user retains exclusive unilateral control of assets.
3. Investment Advisers Act Scope Limitation
INVESTMENT ADVISERS ACT SCOPE LIMITATION:
I CLOSER LTD. maintains an Exempt Reporting Adviser (ERA) filing with the U.S. Securities and Exchange Commission (CRD 338976 / File 802-134747) exclusively applicable to qualified private fund management under Rule 203(m)-1.
Compliance programs established under the Investment Advisers Act of 1940 pertain strictly to private fund operations. The public-facing software, mobile applications, wallet tools, and KernelHub orchestration systems operate independently of investment advisory activities and do NOT provide investment advice, financial portfolio management, or public securities recommendations.
4. Sanctions Enforcement & Geographic Exclusions
SANCTIONS ENFORCEMENT & GEOGRAPHIC EXCLUSIONS:
iCloser enforces strict automated compliance filters and IP/device-level geofencing to prevent access from high-risk and sanctioned jurisdictions:
- Mainland China Prohibition: In accordance with regulatory guidelines, iCloser does not provide services to residents of mainland China. Real-time geofencing actively blocks restricted IP ranges and domestic identifiers.
- OFAC Sanctions Compliance: Services are systematically denied to persons or entities located in comprehensive OFAC-sanctioned jurisdictions (including Cuba, Iran, North Korea, Syria, and the Crimea/Donetsk/Luhansk regions) or appearing on the Specially Designated Nationals (SDN) list.
5. Partner Disclosures
Card-related services, virtual account access, settlement support, and regulated financial services are provided through licensed or authorized third-party partners where applicable.
- Availability may vary by region and eligibility
- Partners may apply independent review standards
- iCloser provides the technology interface, not direct financial institution services
6. Privacy & Security
Identity verification, compliance data, and partner records may be processed by applicable service providers under their own policies and legal obligations.
- Privacy and data protection disclosures
- Security controls for account and wallet access
- Clear separation between wallet infrastructure and regulated partner workflows
7. Travel Rule
Where iCloser or its licensed partners facilitate a transfer that falls within the scope of applicable funds-transfer recordkeeping and transmittal requirements — commonly referred to as the “Travel Rule” — required originator and beneficiary information is collected and transmitted to the receiving institution as required by law.
- Transmittals of USD 3,000 or more — FinCEN Recordkeeping and Travel Rules (31 CFR 1010.410(e)–(f))
- Virtual currency transfers of CAD 1,000 or more — Canada’s PCMLTFA, as administered by FINTRAC
Transfers within scope may require additional information before they can be processed. Where required information cannot be obtained, a transfer may be delayed or declined.
8. AI Workflow Governance & Execution Safety (KernelHub)
AI WORKFLOW GOVERNANCE & EXECUTION SAFETY (KERNELHUB):
iCloser integrates strict compliance and safety guardrails across its AI execution runtime (KernelHub):
- Human-in-the-Loop (HITL): Critical actions—including financial requests, external deployments, and sensitive permission changes—mandate human authorization prior to execution. AI agents may only propose actions, never bypass authorization.
- Least-Privilege Permissions: Execution environments run with bounded file, network, and system privileges under decentralized identity (DID) constraints.
- Auditability & Evidence: All automated executions produce verifiable audit trails, diff logs, and execution artifacts, ensuring transparency, accountability, and deterministic tracking.
iCloser is a non-custodial technology platform. Users retain control of their private keys and digital assets at all times. iCloser does not custody customer funds. Partner-supported services remain subject to eligibility, compliance review, jurisdiction, and applicable law.
