Legal

AML Regulatory Compliance Policy

Last updated: June 2026 · Version 1.0

Anti-Money Laundering Program for Members, Merchants, and Governance Token Holders

Effective Date: June 2026 | Version 1.0 — This policy governs SableAssent Coin Corporation and SableAssent Treasury Reserve SPV LLC merchant and member onboarding.

1. Purpose

SableAssent Coin Corporation and SableAssent Treasury Reserve SPV LLC (together, "SableAssent") maintain a risk-based Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) program designed to detect, prevent, and report money laundering, terrorist financing, fraud, and sanctions evasion across all SableAssent platforms, including sableassent.com, sac1gov.com, and the SableAssent Merchant Payment API.

2. Regulatory Framework

This policy is built to satisfy the following regulatory regimes across SableAssent's operating jurisdictions: U.S. Bank Secrecy Act (BSA) and FinCEN regulations, USA PATRIOT Act, OFAC sanctions regulations, EU Anti-Money Laundering Directives (AMLD5/AMLD6), UK Money Laundering Regulations 2017, UN Security Council Consolidated List, and applicable FATF recommendations.

3. The Five Pillars of the SableAssent AML Program

The SableAssent AML program is built on five foundational pillars required by the Bank Secrecy Act and FATF recommendations.

Pillar 1 — Designated Compliance Officer

SableAssent designates a Chief Compliance Officer (CCO) responsible for overseeing the AML program. The CCO ensures the program meets regulatory requirements, reports to senior management, and maintains independence in decision-making. The CCO has the authority to suspend transactions, freeze accounts, and file Suspicious Activity Reports (SARs).

Pillar 2 — Internal Policies, Procedures, and Controls

SableAssent maintains written AML policies and procedures covering customer onboarding, KYC/CDD, EDD, transaction monitoring, sanctions screening, SAR filing, recordkeeping, and employee training. Policies are reviewed annually and updated as needed.

Pillar 3 — Training and Education

All SableAssent employees receive mandatory AML training upon hire and annually thereafter. Training covers identifying suspicious activity, understanding regulatory obligations, proper escalation procedures, and recognizing red flags.

Pillar 4 — Independent Testing and Audit

SableAssent conducts annual independent audits of its AML program to evaluate effectiveness, identify weaknesses, and ensure compliance with regulatory requirements. Audit results are reported to senior management and the board.

Pillar 5 — Risk-Based Customer Due Diligence

SableAssent employs a risk-based approach to customer due diligence, including: Customer Identification Program (CIP), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD) for high-risk customers, and ongoing monitoring of customer activity.

4. Customer Identification Program (CIP)

All customers must provide: full legal name, date of birth, residential or business address, government-issued identification number, and a copy of a valid government-issued photo ID. For business customers: Certificate of Incorporation, business registration number, tax ID/EIN/VAT number, and identification of beneficial owners (25%+ ownership).

5. Risk Assessment & Risk Rating

Each customer is assigned a risk rating (Low, Medium, High, or Prohibited) based on: customer type, geographic location, transaction patterns, products/services used, PEP status, adverse media screening, and sanctions screening results. High-risk customers undergo Enhanced Due Diligence (EDD).

6. Sanctions Screening

SableAssent screens all customers and transactions against: OFAC Specially Designated Nationals (SDN) List, OFAC Consolidated Sanctions List, EU Consolidated Financial Sanctions List, UK HM Treasury Sanctions List, UN Security Council Consolidated List, and other applicable sanctions lists. Screening occurs at onboarding and on an ongoing basis.

7. Transaction Monitoring

SableAssent monitors transactions for suspicious patterns including: structuring/smurfing, rapid movement of funds, transactions involving high-risk jurisdictions, transactions inconsistent with customer profile, and transactions exceeding reporting thresholds. Suspicious activity is escalated to the CCO for review and potential SAR filing.

8. Suspicious Activity Reporting (SAR)

When suspicious activity is identified, SableAssent files a Suspicious Activity Report (SAR) with the appropriate financial intelligence unit (e.g., FinCEN) within the required timeframe. SABs are filed for transactions that meet or exceed $5,000 in aggregate.

9. Politically Exposed Persons (PEP)

SableAssent screens all customers for PEP status. PEPs are individuals who hold or have held prominent public functions. PEPs undergo Enhanced Due Diligence and require senior management approval before onboarding. Family members and close associates of PEPs are also screened.

10. Recordkeeping

SableAssent maintains records of all customer identification, transaction records, SARs filed, and AML training for a minimum of five (5) years, in accordance with regulatory requirements.

11. Beneficial Ownership Identification

For legal entity customers, SableAssent identifies and verifies the identity of all beneficial owners who own 25% or more of the entity, and the individual with significant managerial control.

12. Prohibited Activities

SableAssent strictly prohibits: transactions involving sanctioned individuals or jurisdictions, money laundering, terrorist financing, structuring to avoid reporting requirements, and use of the platform for any illegal activity. Accounts found in violation are subject to immediate suspension, freezing, and reporting to authorities.

Contact

For questions regarding this AML policy, contact the Chief Compliance Officer at admin@sableassent.com.

SableAssent Coin Corporation · SableAssent Treasury Reserve SPV LLC · 30 N Gould St, Suite 11610, Sheridan, WY 82801 · admin@sableassent.com