AML/CTF Compliance

We are committed to maintaining the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. Our compliance framework is designed to meet regulatory requirements and mitigate risks associated with money laundering and terrorist financing. This document outlines our policies and procedures to ensure compliance with North American regulations and international standards.

Scope

This AML/CTF compliance policy applies to all activities conducted by Eden, including the issuance, trading, and management of multiple tokens such as stable tokens, bridge tokens, and utility tokens within our ecosystem. It also encompasses our on-ramp services, Dogechain integration using WDOGE as gas, zkEVM operations, and staking features (no lockups, 11x).

Regulatory Compliance

North American Regulations

We adhere to all relevant AML/CTF regulations in North America, including:

• The Bank Secrecy Act (BSA): We implement comprehensive record-keeping and reporting protocols to comply with the BSA requirements.
• USA PATRIOT Act: Our procedures ensure compliance with enhanced due diligence and reporting obligations mandated by the USA PATRIOT Act.
• Financial Action Task Force (FATF) Recommendations: We align our practices with the FATF’s international standards for combating money laundering and terrorist financing.
• Canadian Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA): We comply with Canadian regulations, including customer identification and reporting obligations.

AML/CTF Framework

Customer Due Diligence (CDD)

We implement stringent CDD measures to verify the identity of our customers. This includes:

• Know Your Customer (KYC): Collecting and verifying customer information through government-issued identification and other reliable sources.
• Enhanced Due Diligence (EDD): Applying additional scrutiny to high-risk customers, transactions, and geographical locations.

Transaction Monitoring

We employ advanced monitoring systems to detect and report suspicious activities. This includes:

• Real-Time Monitoring: Continuous surveillance of transactions to identify unusual patterns or activities.
• Threshold Reporting: Reporting transactions that exceed specified thresholds to regulatory authorities.

Record Keeping

We maintain comprehensive records of all transactions, customer interactions, and compliance activities for a minimum of five years, as required by law.

Risk Assessment

We conduct regular risk assessments to identify and mitigate potential AML/CTF risks associated with our operations. This includes evaluating the risk profile of our products, services, and customer base.

Training and Awareness

Our employees receive ongoing training on AML/CTF policies and procedures to ensure they understand their responsibilities and can effectively identify and report suspicious activities.

Reporting Obligations

We fulfill our reporting obligations by promptly submitting Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) to the relevant authorities.

Compliance Officer

Our dedicated AML/CTF Compliance Officer is responsible for overseeing our compliance program, conducting risk assessments, and ensuring adherence to all regulatory requirements.

Geographic Availability

Our crypto wallet and its ecosystem of tokens, including the use of WDOGE as gas on Dogechain, are available in countries that have embraced blockchain technology. We continuously monitor the regulatory landscape to ensure compliance and availability where legally permitted.

Eden is dedicated to maintaining a robust AML/CTF compliance program to protect our customers and the integrity of our operations. We continuously review and enhance our policies and procedures to ensure we meet regulatory requirements and best practices.