1. Purpose
This AML / KYC Policy ("Policy") describes the measures taken by Pocketfolio (CORPORATE ID: 3-102-938342) ("Pocketfolio," "we," "our," or "us") to prevent the use of its Platform for money laundering, terrorist financing, fraud, or other financial crimes.
Pocketfolio is committed to full compliance with applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) laws, as well as international best practices, including the recommendations of the Financial Action Task Force (FATF).
This Policy applies to all users, employees, contractors, and partners of Pocketfolio globally.
2. Policy Objectives
Pocketfolio’s AML/KYC program aims to:
- Identify and verify all users (individual and corporate);
- Monitor transactions for suspicious activity;
- Maintain transparent records of trades, deposits, and withdrawals;
- Cooperate with regulatory and law-enforcement authorities when required;
- Prevent misuse of crypto assets for illicit purposes.
3. Scope
This Policy applies to all products and services offered by Pocketfolio, including:
- API-linked account automation;
- Custodial digital asset management;
- Deposits, withdrawals, and internal transfers;
- Referral and partner programs.
4. Legal Framework
Pocketfolio operates under the laws of Costa Rica and complies with:
- FATF Recommendations;
- The OECD’s Common Reporting Standard (CRS) principles;
- EU 5th & 6th AML Directives (for EU users);
- FinCEN guidance (for USD-linked transactions);
- Applicable local AML legislation is required by our banking, custodial, or exchange partners.
5. Customer Identification (KYC)
Pocketfolio requires mandatory identity verification for all users before granting full access to the platform.
a. Individual Members
Each individual must provide:
- Full legal name;
- Date of birth;
- Residential address;
- Government-issued photo ID (passport, national ID, or driver’s license);
- Proof of address (utility bill, bank statement, or government correspondence dated within 3 months);
- (If applicable) selfie or live verification to confirm likeness.
b. Corporate Members (Entities, Funds, or Institutions)
Each legal entity must provide:
- Certificate of incorporation or business registration;
- Memorandum and Articles of Association (or equivalent);
- List of directors and authorised signatories;
- Identification and proof of address for Ultimate Beneficial Owners (UBOs) holding ≥25%;
- Business address and operational contact information;
- Nature and purpose of the business relationship with Pocketfolio.
Pocketfolio reserves the right to request additional documentation or enhanced due diligence (EDD) for higher-risk users, such as complex structures or politically exposed persons (PEPs).
6. Verification Procedures
Verification is performed via trusted third-party KYC providers that meet international compliance standards.
Pocketfolio may also conduct manual reviews of documents and cross-check user data against:
- Government sanctions and watchlists (OFAC, UN, EU, etc.);
- Politically Exposed Person (PEP) databases;
- Adverse media and global enforcement lists.
Pocketfolio will not onboard users who appear on restricted or sanctions lists.
7. Risk-Based Approach
Pocketfolio employs a risk-based approach (RBA) to AML compliance.
Members and transactions are categorised as low, medium, or high risk, depending on factors such as:
- Jurisdiction of residence;
- Transaction volume and frequency;
- Source of funds;
- Connection to high-risk industries or counterparties.
High-risk accounts are subject to enhanced monitoring and manual review of compliance.
8. Ongoing Monitoring
Pocketfolio continuously monitors member activity and transaction patterns to identify:
- Large, rapid, or unusual transfers;
- Repeated deposits or withdrawals with no economic rationale;
- Activity inconsistent with the user’s known profile;
- Interaction with sanctioned or suspicious wallets.
Automated systems flag potential risks for review by the compliance officer.
9. Source of Funds and Wealth
Pocketfolio may request proof of source of funds or source of wealth for specific users, especially when:
- Large deposits are made.
- The user’s jurisdiction is classified as high-risk.
- Transactions exceed compliance thresholds.
Acceptable documentation may include bank statements, payslips, audited financial statements, or proof of cryptocurrency holdings.
10. Record Keeping
All KYC documentation, verification logs, and transaction records are securely stored for a minimum of five (5) years after the end of the business relationship or longer if required by law.
Records are encrypted and accessible only to authorised compliance staff.
11. Reporting Suspicious Activity
Pocketfolio's compliance team maintains a process for identifying and reporting Suspicious Activity Reports (SARs) to the relevant authorities, as required by law.
Suspicious behaviour includes, but is not limited to:
- Attempting to bypass KYC verification.
- Structuring deposits to avoid limits.
- Transactions linked to high-risk wallets or entities.
- False or fraudulent information submission.
Members are not notified if a SAR is filed.
12. Restricted Jurisdictions
Pocketfolio does not accept users, directly or indirectly, from jurisdictions subject to international sanctions or where cryptocurrency trading is prohibited.
This includes (but is not limited to):
United States, North Korea, Iran, Syria, Cuba, Crimea, Donetsk, and Luhansk regions.
13. Employee Training and Compliance Oversight
Pocketfolio provides regular AML/CFT training to staff and contractors.
A Designated Compliance Officer (DCO) oversees the AML program, ensuring:
- Consistent policy enforcement.
- Internal audit reviews.
- Timely regulatory updates.
- Cooperation with law enforcement and regulators.
14. Data Protection
All personal data collected during KYC and AML procedures is processed in accordance with our Privacy Policy and applicable data protection laws (including GDPR).
Sensitive information is encrypted both in transit and at rest.
15. Refusal or Termination of Service
Pocketfolio reserves the right to:
- Decline onboarding of any user who fails KYC/AML verification;
- Suspend or terminate accounts showing suspicious activity;
- Freeze or return assets subject to investigation or legal order.
Pocketfolio will cooperate fully with law enforcement in such cases.
16. Policy Updates
This AML/KYC Policy may be updated periodically to reflect changes in regulation or business practices.
Updated versions will be posted on the Pocketfolio website.
17. Contact Information
For compliance inquiries or document submissions:
Pocketfolio (CORPORATE ID: 3-102-938342)
Corporate ID: 3-102-938342
(3-102-938342 SOCIEDAD DE RESPONSABILIDAD LIMITADA)
Registered Address: SAN JOSÉ MONTES DE OCA SAN PEDRO, PROVINCE ONE SAN JOSÉ, COUNTY FIFTEEN MONTES DE OCA, DISTRICT ONE OF SAN PEDRO, LOS YOSES, AVENUES EIGHT AND TEN, STREET THIRTY NINE, LY CENTER, San José, Costa Rica
