This Policy establishes the compliance framework adopted by Smart Property Solutions Ltd ("SPS") for digital asset, stablecoin and related financial intermediation activities, ensuring responsible customer onboarding, transaction monitoring, sanctions compliance and risk management.
This Anti-Money Laundering (AML), Counter Financing of Terrorism (CFT), Counter Proliferation Financing (CPF) and Targeted Financial Sanctions (TFS) Policy establishes the compliance framework adopted by Smart Property Solutions Ltd ("SPS") to prevent the company from being used for money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud and other financial crime.
The Policy applies to SPS's payment processing, payroll services and its proposed structured digital asset and stablecoin brokerage facilitation operations, including Native USDT and, where approved, Tether Gold (XAUT).
Payment processing and payroll-related services supported by customer due diligence, sanctions screening, transaction monitoring and record keeping.
Structured brokerage facilitation for Native USDT and approved digital assets, subject to regulatory approval and internal compliance controls.
Services are designed for institutional, corporate and qualified professional clients within approved jurisdictions.
This Policy should be read together with all applicable laws, regulatory guidance, licence conditions, banking partner requirements and approved digital asset operating standards. Where there is any uncertainty or conflict between commercial objectives and compliance obligations, the stricter compliance control shall apply until reviewed and approved by the Compliance Officer, Principal Officer and Director.
| Role | Primary Responsibilities |
|---|---|
| Director / Board | Approves this Policy, risk appetite, product scope, high-risk relationships and material business changes. |
| Principal Officer | Oversees day-to-day management of licensed operations and approved digital asset activities. |
| Compliance Officer | Maintains AML/CFT controls, onboarding approval, sanctions screening, transaction monitoring and regulatory reporting. |
| Operations | Collects customer documentation, verifies instructions and escalates unusual transactions. |
| Technology | Maintains cybersecurity, API controls, audit logs, wallet approval workflows and system integrity. |
| Employees | Comply with this Policy, complete mandatory training and report suspicious activities. |
SPS adopts a risk-based approach to customer onboarding and transaction monitoring. Every customer relationship is assessed according to customer, geographical, product, transaction, delivery channel, wallet, blockchain network and counterparty risk.
| Risk Level | Description | Minimum Controls |
|---|---|---|
| Low | Regulated, transparent customers with straightforward ownership, low-risk jurisdictions and predictable business activity. |
|
| Medium | Cross-border activity, higher transaction volumes, or more complex ownership structures. |
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| High | PEPs, VASPs, high-risk jurisdictions, complex ownership, high transaction values or elevated blockchain risk. |
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SPS will only send digital assets to, or receive digital assets from, wallets that have successfully completed wallet verification, sanctions screening, blockchain risk screening and internal approval. Each approved wallet shall be linked to:
Any modification to a wallet address, supported blockchain network or ownership information requires a new compliance review before further transactions are permitted.
| Stage | Minimum Requirement |
|---|---|
| Before Onboarding | Screen all declared wallets and associated wallet clusters. |
| Before Transaction | Screen source wallet, destination wallet, counterparty and transaction route. |
| After Transaction | Monitor confirmation, transaction hash, network and post-transaction alerts. |
| Ongoing Monitoring | Re-screen approved wallets periodically and immediately after new sanctions or blockchain alerts. |
| Alert Handling | Escalate medium and high-risk alerts to the Compliance Officer before transaction release. |
Transaction reconciliation
Blockchain confirmation
Compliance review
Customer profile update
| Trigger | Required Action |
|---|---|
| Transaction exceeds expected volume | Compliance review before execution. |
| New wallet or blockchain network | Fresh screening and approval. |
| Third-party funding request | Enhanced Due Diligence. |
| Medium or High blockchain alert | Hold processing pending investigation. |
| Customer refuses information request | Suspend processing and assess relationship. |
| Transaction inconsistent with profile | Enhanced monitoring and possible STR. |
USDT is used only as an approved digital settlement asset for client-driven transactions. SPS does not engage in speculative proprietary trading.
| Control | Requirement |
|---|---|
| Supported Networks | Maintain an approved list of blockchain networks. |
| Network Selection | Confirm blockchain network before execution. |
| Native USDT | Supply only approved native USDT. |
| Unsupported Networks | Reject unsupported assets and blockchain networks. |
| Reconciliation | Record wallet, transaction hash, amount and fees. |
SPS may facilitate Tether Gold (XAUT) transactions for eligible institutional and corporate clients subject to regulatory approval.
Employees must not disclose that an investigation or Suspicious Transaction Report has been filed or may be filed.
SPS maintains accurate, complete and retrievable records for customer onboarding, transaction processing, compliance reviews and digital asset activities. Records shall be retained for a minimum of seven (7) years from the completion of a transaction or termination of the customer relationship, or longer where required by law, regulatory investigation or litigation hold.
This Policy shall be reviewed at least annually and whenever there is a material change to SPS's business model, digital asset scope, regulatory framework, blockchain networks, custody arrangements, technology platform, transaction volumes, customer base or risk appetite.
| Approval Item | Approving Authority | Frequency |
|---|---|---|
| AML / CFT Policy | Director / Board | Annual |
| Digital Asset Products | Director / Board | Before Launch |
| High-Risk Customer | Director | Before Onboarding |
| High-Risk Transaction | Compliance Officer / Principal Officer | Before Execution |
| Compliance Vendors | Director / Board | Annual Review |