Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

1. Purpose and Scope

1. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the measures Easy Peasy Inc. ("Easy Peasy," "we," or "our") takes to prevent money laundering, terrorist financing, fraud, and other financial crimes.
2. We operate under the U.S. Bank Secrecy Act (BSA) and comply with the Financial Crimes Enforcement Network (FinCEN) requirements, as well as all applicable state and federal laws of the United States.
3. Easy Peasy Inc. provides cryptocurrency-to-cash exchange services exclusively in person within the State of California, USA. We do not conduct or support online trading, remote exchanges, or digital wallet services.

2. Regulatory Registration

1. Easy Peasy Inc. is officially registered as a Money Services Business (MSB) with FinCEN under registration number 31000284801399. Our AML program is designed to meet or exceed FinCEN and DFPI standards for recordkeeping, reporting, and customer verification.

3. AML Compliance Program

Our AML program includes the following key components:

1. Internal Policies and Procedures – designed to identify and report suspicious activities and prevent the misuse of our services.
2. Compliance Officer – a designated officer oversees program implementation, reporting, and coordination with regulators.
3. Employee Training – all staff receive regular AML/KYC and compliance training.
4. Independent Review – the AML program is periodically reviewed and tested by independent auditors.

4. Customer Identification (KYC / CIP)

1. We verify every customer's identity in person before providing any exchange service. As part of our Customer Identification Program (CIP), customers must present a valid government-issued photo ID and complete required verification steps.
2. We collect and maintain the following information: Full name, Date of birth, Residential address, Identification number (passport, driver's license, etc.)
3. All collected information is used solely for compliance purposes and stored securely in accordance with our Privacy Policy (https://easypeasy.exchange/en/legal/privacy).

5. Customer Due Diligence (CDD / EDD)

1. Easy Peasy applies risk-based due diligence measures to all customers. Enhanced Due Diligence (EDD) is conducted for higher-risk individuals, including Politically Exposed Persons (PEPs) or those connected to high-risk jurisdictions identified by the FATF.
2. Customers may be asked to provide additional documentation or source-of-funds information when required by law or internal review.

6. Monitoring and Reporting

1. All transactions are reviewed for consistency with the customer's profile and applicable regulations. If any activity appears unusual, inconsistent, or potentially suspicious, Easy Peasy may: conduct additional verification, delay or refuse the transaction, and/or file a Suspicious Activity Report (SAR) with FinCEN.
2. Easy Peasy cooperates fully with U.S. law enforcement and regulatory agencies.
3. In-Person Exchange Model: Easy Peasy conducts all exchanges exclusively in person at its physical offices in California. We do not facilitate online trading, remote exchange, or digital wallet services. This structure ensures complete transparency of every transaction and significantly reduces AML risk exposure.

7. Record Retention

1. All AML/KYC records — including identification data, transaction information, and reports — are securely retained for a minimum of five (5) years in accordance with the Bank Secrecy Act (31 CFR §1022.410).
2. Employee Accountability: Every employee of Easy Peasy Inc. involved in handling cryptocurrency or cash is trained to identify suspicious activity and immediately report findings to the Compliance Officer. Each team member is personally responsible for following this AML/KYC Policy and upholding compliance standards as part of their employment duties.

8. Data Privacy and Protection

1. All information collected under this AML/KYC Policy is handled with strict confidentiality and used only for regulatory compliance. We do not sell or share personal information for commercial purposes. For detailed information on data handling and user rights, please refer to our Privacy Policy (https://easypeasy.exchange/en/legal/privacy).

9. Legal Compliance and Sanctions

1. Easy Peasy Inc. complies with all applicable sanctions programs administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC). We do not engage in transactions involving sanctioned individuals, entities, or jurisdictions.
2. Annual Review and Updates: This AML/KYC Policy is reviewed annually, or sooner if regulatory changes occur. The updated version is published on our website and made available to regulators or partners upon request.
3. Whistleblower and Reporting Channel: Easy Peasy encourages both employees and customers to report any suspicious activity or potential violations of this policy confidentially to [email protected]. All reports are handled discreetly and without retaliation.

10. Contact Information

1. Compliance Department – Easy Peasy Inc.
2. Email: [email protected]
3. Address: 109 W Wilson Ave, #219, Glendale, CA 91203, USA