AML/KYC POLICY
Effective: June 2026
1. PURPOSE AND SCOPE
This Policy establishes the Anti-Money Laundering (AML), Know Your Customer (KYC), Customer Identification Program (CIP), sanctions compliance, and investor due diligence standards of BitHouse, Inc. The Policy applies to all BitHouse-sponsored products, including the BITS USD Reserve Fund, BITS USD Fixed Income Notes, BITS Real Estate Fund (USA), BITS Magic Seven Income Fund, BITS Magic Seven Growth Fund, and future affiliated investment vehicles.
2. AML COMPLIANCE PROGRAM
BitHouse prohibits money laundering, terrorist financing, sanctions evasion, fraud, and other illicit financial activity. The Company shall maintain risk-based controls designed to identify, assess, monitor, and mitigate financial crime risks.
3. AML COMPLIANCE OFFICER
BitHouse shall designate a Compliance Officer responsible for AML/KYC oversight, sanctions screening, employee training, record retention, investigations, and annual policy review.
4. CUSTOMER IDENTIFICATION PROGRAM (CIP)
Before opening an account or accepting an investment, BitHouse shall collect and verify the investor's legal name, date of birth, address, government identification, contact information, wallet addresses, and other information necessary to establish identity.
5. KNOW YOUR CUSTOMER (KYC) REQUIREMENTS
BitHouse shall conduct risk-based KYC reviews for all investors, including individuals, entities, trusts, partnerships, and corporations. Additional documentation may be required depending on risk level.
6. ACCREDITED INVESTOR VERIFICATION
For applicable offerings, BitHouse may verify accredited investor status through tax returns, CPA letters, attorney letters, investment adviser certifications, or approved third-party verification providers.
7. BENEFICIAL OWNERSHIP
For legal entities, BitHouse shall identify beneficial owners owning 25% or more of the entity and any individual exercising significant control. Enhanced ownership reviews may be conducted where warranted.
8. POLITICALLY EXPOSED PERSONS (PEPS)
PEPs and related persons shall be subject to Enhanced Due Diligence, source-of-wealth review, senior management approval, and ongoing monitoring.
9. SANCTIONS SCREENING
BitHouse shall screen investors against OFAC, UN, EU, UK, and other applicable sanctions lists before onboarding and periodically thereafter.
10. DIGITAL ASSET AND BLOCKCHAIN MONITORING
BitHouse may utilize blockchain analytics tools to identify high-risk wallets, sanctions exposure, darknet activity, mixers, ransomware indicators, and other suspicious activity.
11. SOURCE OF FUNDS AND SOURCE OF WEALTH
BitHouse may require investors to provide documentation demonstrating the lawful origin of investment funds and overall source of wealth.
12. REGULATION D AND REGULATION S INVESTORS
BitHouse may accept U.S. and non-U.S. investors subject to applicable securities laws and enhanced verification procedures.
13. SUSPICIOUS ACTIVITY MONITORING
BitHouse shall monitor transactions, subscriptions, redemptions, distributions, wallet transfers, and investor activity for indicators of suspicious conduct.
14. REPORTING AND ESCALATION
Potential suspicious activity shall be escalated to the Compliance Officer. Reports may be made to regulatory authorities or law enforcement where required by law.
15. RECORD RETENTION
Investor identification records shall be maintained for a minimum of five years after account closure. Subscription records and compliance documentation should generally be retained for at least seven years.
16. TRAINING
Relevant personnel shall receive AML/KYC training at least annually.
17. CONFIDENTIALITY
Compliance reviews, investigations, and reports shall be treated as confidential and shared only on a need-to-know basis.
18. ANNUAL REVIEW
This Policy shall be reviewed at least annually and updated to reflect changes in law, regulation, products, technology, and business operations.