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Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) Policy

BONDI TECHNOLOGY INC.
Effective Date: February 10, 2025

1. Introduction and Commitment​

Bondi Technology Inc. ("Bondi," "we," "us," or "our") is committed to preventing the use of our platform for money laundering, terrorist financing, or other illicit activities. This AML/CFT Policy outlines our comprehensive approach to detecting, preventing, and mitigating such risks while providing our tokenized bond services.

While operating in Panama where crypto activities currently have limited specific regulations, Bondi voluntarily adopts international best practices, including:

  • Recommendations from the Financial Action Task Force (FATF)
  • Principles from the EU's 5th Anti-Money Laundering Directive
  • Relevant aspects of the Bank Secrecy Act (BSA)

3. Risk-Based Approach​

3.1 Risk Assessment​

Bondi conducts regular risk assessments considering:

  • User risk profiles
  • Geographic risk factors
  • Product/service risks
  • Transaction patterns
  • Delivery channel risks

3.2 Risk Mitigation​

We implement controls proportional to identified risks, including:

  • Enhanced due diligence for high-risk users
  • Blockchain analytics for transaction monitoring
  • Ongoing screening against sanctions lists
  • Smart contract enforcement of KYC requirements

4. Know Your Customer (KYC) Procedures​

4.1 Third-Party KYC Provider​

Bondi has partnered with Sumsub, a trusted global KYC/AML service provider also used by leading cryptocurrency exchanges such as Bybit and Huobi, to implement robust verification procedures and ensure compliance with international standards.

4.2 User Identification​

All users must provide and verify through Sumsub's verification platform:

  • Full legal name
  • Date of birth
  • Email address
  • Government-issued photo identification
  • Proof of address (utility bill, bank statement)
  • Liveness verification (via selfie or video)

4.3 Customer Due Diligence (CDD)​

Standard verification procedures include:

  • Document authenticity verification
  • Cross-referencing personal information
  • Wallet address verification
  • Screening against sanctions lists
  • Verification of residence outside restricted jurisdictions

4.4 Enhanced Due Diligence (EDD)​

Applied to higher-risk scenarios:

  • Politically Exposed Persons (PEPs) at all levels, including:
    • Heads of State, National Parliaments, National governments (PEP Class 1)
    • Regional governments, Regional parliaments (PEP Class 2)
    • Senior management & Board of SOEs (PEP Class 3)
    • Mayors and members of local city councils (PEP Class 4)
    • Unclassified PEPs
  • High-value transactions (exceeding $50,000 USD equivalent)
  • Users from higher-risk jurisdictions
  • Unusual transaction patterns

5. Transaction Monitoring​

5.1 Ongoing Monitoring​

We employ:

  • Automated blockchain analytics tools
  • Pattern recognition algorithms
  • Transaction volume and frequency monitoring
  • Source of funds verification for large transactions

5.2 Suspicious Activity Indicators​

Red flags include:

  • Rapid succession of transactions
  • Unusual transaction sizes
  • Transactions with high-risk jurisdictions

6. Wallet Controls and Intervention Measures​

6.1 Smart Contract Enforcement​

Our platform implements on-chain enforcement of KYC requirements through our verified and immutable smart contracts

  • Only KYC-verified wallets can deposit funds
  • Wallet verification status is managed by our secure backend
  • KYC completion is registered only after successful Sumsub verification
  • Users connect their self-custodial wallets or create self-custodial in-app wallets with their social accounts

6.2 Wallet Restrictions​

As a decentralized application, Bondi implements security measures at the smart contract and frontend levels:

  • Blacklisting of wallets associated with suspicious activity
  • Prevention of contract interactions from non-KYC verified wallets
  • Frontend-level restrictions for non-KYC verified wallets

6.3 Blockchain Analytics​

We utilize specialized tools to:

  • Trace transaction flows
  • Identify high-risk wallet addresses
  • Monitor for connections to known illicit activities

7. Sanctions and Watchlist Screening​

Users are screened against multiple databases and watchlists, including:

  • Sanctions lists (OFAC and local sanctions lists)
  • Warning lists (wanted persons, disqualified directors)
  • Fitness and Probity databases (e.g., US System for Award management exclusions)
  • Adverse media mentions
  • PEP databases at all classification levels

8. Restricted Jurisdictions​

Bondi strictly prohibits users from jurisdictions subject to:

  • Comprehensive sanctions
  • FATF blacklisting
  • Identified as high-risk for money laundering or terrorism financing

These restricted jurisdictions include, but are not limited to: Afghanistan, Albania, Belarus, Bosnia and Herzegovina, Central African Republic, Congo (Brazzaville), Cuba, Hong Kong, Iran, Iraq, Côte d'Ivoire, Lebanon, Libya, Mali, Myanmar, Nicaragua, North Korea, Russia, Serbia, Slovenia, Somalia, South Sudan, Sudan, Syrian Arab Republic, United States of America, Venezuela, Yemen, Zimbabwe, Angola, Algeria, Burkina Faso, Cameroon, Croatia, Congo (Kinshasa), Haiti, Kenya, Monaco, Mozambique, Namibia, Nigeria, Philippines, South Georgia and the South Sandwich Islands, South Africa, Tanzania, Viet Nam, Palestine, U.S. Minor Outlying Islands, U.S. Virgin Islands.

Bondi employs robust geofencing, IP monitoring, and document verification to enforce these restrictions.

9. Record Keeping​

Bondi maintains:

  • KYC documentation for 5 years after last platform interaction
  • Transaction records and blockchain data
  • Due diligence findings and risk assessments
  • Communication records related to suspicious activities

10. Suspicious Activity Reporting​

10.1 Security Team Monitoring​

Our security team monitors the platform for suspicious activities and patterns that may indicate money laundering or terrorist financing.

10.2 External Reporting​

Where legally required, Bondi will:

  • File Suspicious Activity Reports (SARs) with appropriate authorities
  • Collaborate with law enforcement inquiries
  • Report significant security incidents

11. Policy Review and Updates​

This policy undergoes:

  • Annual comprehensive review
  • Updates following significant regulatory changes
  • Adaptation to emerging threats and typologies

12. Consequences of Non-Compliance​

Wallets found violating this policy may face:

  • Blocklisting at the smart contract level
  • Prevention of further token transfers or interactions
  • Force-transfer of tokens in cases of severe violations
  • Reporting to relevant authorities where legally required

Contact Information​

For security and compliance inquiries:

Email: info@bondifinance.io

Registered Address:
Bondi Technology Inc.
Province of Panama, District of Panama, Betania,
Vía Ricardo J. Alfaro, PH The Century Tower, Office 317