KYC/AML Policy

1Policy Overview

ARTSMEGA GLOBAL NETWORK is committed to preventing money laundering, terrorist financing, and other financial crimes. This KYC/AML (Know Your Customer / Anti-Money Laundering) Policy outlines our compliance framework, risk-based approach, and obligations under international regulations. This policy also covers verification procedures for our Social Protection System benefits.

2Risk-Based Approach (RBA)

We implement a risk-based approach to KYC/AML compliance, applying proportionate measures based on assessed risk levels:

3Customer Due Diligence (CDD)

3.1 Standard Due Diligence

For all users, we collect and verify:

• • Full legal name
• • Email address
• • Date of birth
• • Country of residence
• • Cryptocurrency wallet addresses (for transactions)

3.2 Enhanced Due Diligence (EDD)

For high-value withdrawals (above $10,000 USD equivalent) or high-risk profiles, we require:

• • Government-issued photo ID (passport, national ID, driver's license)
• • Proof of address (utility bill, bank statement dated within 3 months)
• • Source of funds declaration
• • Selfie verification holding ID document
• • Additional documentation as required

4Social Protection Verification

The Social Protection System requires additional verification procedures to ensure benefit eligibility and prevent fraud:

4.1 Family Member Verification

To add covered family members (spouse, children), we require:

• • Spouse: Valid marriage certificate, government-issued photo ID of spouse
• • Children: Birth certificate showing parent relationship, government-issued ID if over 16
• • All documents must be official, legible, and not expired
• • Documents in non-English languages must include certified translations
• • Admin review within 24-72 hours

4.2 Beneficiary Verification

To designate death benefit beneficiaries, we require:

• • Full legal name and relationship to artist
• • Valid cryptocurrency wallet address
• • Share percentage (all beneficiaries must total 100%)
• • Government-issued ID for each beneficiary
• • Proof of relationship where applicable

4.3 Death Benefit Claim Verification

To process death benefit claims, we require:

• • Official death certificate issued by government authority
• • Certified translation if not in English
• • Verification of beneficiary identity matching registered records
• • Proof of relationship to deceased artist
• • Valid cryptocurrency wallet for payment receipt
• • Extended review period (up to 30 days) for complex cases

4.4 Healthcare Provider Verification

To approve healthcare providers in our network, we verify:

• • Valid business registration and licenses
• • Medical facility accreditation
• • Legitimate cryptocurrency wallet for receiving payments
• • Pricing agreements and service offerings
• • Physical location and contact information
• • Ongoing compliance monitoring

4.5 Medical Claim Verification

Medical claims follow a provider-initiated process:

• • Claim Submission: Only approved healthcare providers can submit claims—artists cannot submit claims directly
• • Service Documentation: Providers must include diagnosis, treatment details, itemized services, and agreed pricing
• • Artist Confirmation: Artists must sign/confirm receipt of all services listed in the claim
• • Signature Verification: Digital signatures are timestamped and recorded for audit trail
• • Discrepancy Reporting: Artists must report any services listed that were not actually received
• • Admin Review: All claims reviewed within 24-72 hours before payment processing
• • Fraud Prevention: Cross-verification between provider claims and artist confirmations

5Verification Process

6Transaction Monitoring

We implement automated and manual transaction monitoring to detect suspicious activity:

• • Threshold Monitoring: Large transactions automatically flagged for review
• • Pattern Analysis: Unusual activity patterns identified and investigated
• • Velocity Checks: Rapid succession of transactions monitored
• • Geographic Risk: Transactions involving high-risk jurisdictions flagged
• • Behavioral Analysis: Deviations from normal user behavior reviewed
• • Claims Monitoring: Provider-submitted claims checked for frequency, amounts, and patterns
• • Confirmation Tracking: Artist service confirmations cross-verified with provider claims
• • Provider Payments: Healthcare provider payment patterns analyzed

7Suspicious Activity Reporting (SAR)

We maintain robust SAR procedures:

• • Suspicious activities identified through monitoring or reported by staff
• • Internal investigation conducted by compliance team
• • SARs filed with appropriate authorities (FinCEN, national FIUs) as required
• • Records maintained for regulatory inspection
• • Fraudulent Social Protection claims reported to relevant authorities

8Prohibited Activities

The following activities are strictly prohibited and will result in account termination and reporting:

• • Money laundering or attempting to launder funds
• • Terrorist financing or supporting designated entities
• • Fraud, embezzlement, or theft
• • Tax evasion or avoidance schemes
• • Sanctions violations
• • Structuring transactions to avoid reporting thresholds
• • Using the platform for illegal activities
• • Providing false identity documents
• • Operating accounts on behalf of third parties without disclosure
• • Signing false confirmations for services not actually received
• • Providing false family member or beneficiary documentation
• • Colluding with healthcare providers for fraudulent claims
• • Submitting forged death certificates or other legal documents
• • Failing to report discrepancies in healthcare provider claims

9Sanctions Screening

We screen all users, beneficiaries, and healthcare providers against international sanctions lists:

• • OFAC (Office of Foreign Assets Control) SDN List
• • EU Consolidated Sanctions List
• • UN Security Council Sanctions List
• • UK HM Treasury Sanctions List
• • Other applicable national and international sanctions lists

Positive matches result in account freezing and reporting to appropriate authorities. Healthcare providers in sanctioned jurisdictions are not eligible for our network.

10Restricted Jurisdictions

ARTSMEGA does not provide services to residents of:

This list may be updated based on changing international sanctions and regulations. Healthcare providers in these regions are not eligible for our Social Protection network.

11Politically Exposed Persons (PEPs)

Enhanced due diligence is applied to PEPs and their close associates. PEPs include:

• • Heads of state, government ministers, senior politicians
• • Senior judicial or military officials
• • Senior executives of state-owned corporations
• • Important political party officials
• • Family members and close associates of the above

PEP status does not automatically disqualify users, but triggers enhanced monitoring and source of wealth verification.

12Record Keeping

We maintain comprehensive records as required by law:

• • Identity Records: Copies of ID documents, verification results - 5 years after account closure
• • Transaction Records: All financial transactions - 5-7 years
• • Correspondence: Communications related to due diligence - 5 years
• • SAR Records: Suspicious activity reports and investigations - 5 years
• • Training Records: Staff AML training completion - 5 years
• • Social Protection Documents: Family member certificates, beneficiary records - 10 years
• • Medical Claims: Claim documentation and provider payments - 7 years
• • Death Benefit Claims: Death certificates, payout records - 10 years

13Staff Training & Awareness

All ARTSMEGA staff receive regular AML training covering identification of suspicious activity, reporting obligations, sanctions compliance, and regulatory updates. Staff handling Social Protection claims receive additional training on document verification, fraud detection, and healthcare provider compliance. Training is refreshed annually and upon significant regulatory changes.

14User Obligations

By using ARTSMEGA, you agree to:

15Compliance Officer

ARTSMEGA has appointed a Money Laundering Reporting Officer (MLRO) responsible for overseeing our AML compliance program, receiving internal suspicious activity reports, filing SARs with authorities, and ensuring ongoing compliance with regulations. The MLRO also oversees Social Protection verification procedures and fraud prevention measures.