This KYC/AML Compliance Agreement (the “Agreement”) is entered into as of the date of acceptance by the undersigned party (the “User” or “Investor”), and governs the Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) requirements applicable to all participants engaging with BlockEstateDAO, LLC (“BlockEstateDAO” or the “DAO”). By purchasing, holding, or transacting with BESD Tokens or participating in any DAO-related activities, the User agrees to comply with this Agreement and all applicable KYC/AML laws and regulations.

  • Purpose

This Agreement sets forth the KYC and AML compliance obligations of all Users and Investors to ensure that BlockEstateDAO adheres to international regulations aimed at preventing illicit activities, including but not limited to: 

  • Money laundering
  • Terrorist financing
  • Fraudulent transactions
  • Sanctions violations
  • Other financial crimes

This Agreement applies to any person or entity participating in BlockEstateDAO’s token sales, transactions, staking, governance, or treasury activities.

  • Regulatory Compliance

BlockEstateDAO is committed to compliance with the relevant KYC/AML regulatory frameworks, including but not limited to: 

  • United States: Bank Secrecy Act (BSA), USA PATRIOT Act, Financial Crimes Enforcement Network (FinCEN) regulations
  • United Kingdom: Money Laundering Regulations 2017 (MLR), Proceeds of Crime Act (POCA)
  • Dominican Republic: Law No. 155-17 Against Money Laundering and Terrorism Financing
  • Global Compliance Standards: FATF (Financial Action Task Force) guidelines, European Union AML Directives (AMLD)

  • KYC Verification Process

All Users and Investors must undergo KYC verification before participating in BlockEstateDAO’s activities, including but not limited to: 

  • Token purchases from BlockEstateDAO or participation in token sales
  • Staking and governance participation
  • Fund withdrawals
  • Any transaction exceeding a threshold determined by the DAO’s compliance policies

Users who acquire BESD tokens through secondary markets and do not engage in any DAO activities (e.g., voting, staking, treasury withdrawals) are not required to complete KYC verification.

3.1 Required Information

To complete the KYC process, the User must provide:

  • Individuals:
    • Full legal name
    • Date of birth
    • Government-issued identification (passport, driver’s license, or national ID)
    • Proof of residential address (utility bill or bank statement issued within the last 3 months)
    • Selfie verification (photo of User holding their ID)
  • Entities (Corporate Investors or Institutions):
    • Legal entity name and registration details
    • Certificate of incorporation
    • List of beneficial owners (25%+ ownership)
    • Identification of authorized signatories
    • Proof of business address
    • Tax identification number (if applicable)

3.2 KYC Provider

BlockEstateDAO may engage third-party KYC/AML service providers to process identity verification. Users consent to the collection, storage, and processing of their personal data in accordance with BlockEstateDAO’s Privacy Policy.

3.3 Periodic KYC Updates

Users may be required to update their KYC information periodically or upon request by BlockEstateDAO.

4. AML Screening & Compliance Checks

4.1 AML Monitoring

BlockEstateDAO employs automated and manual monitoring systems to detect suspicious transactions, including:

  • High-value transactions
  • Rapid movements of funds across multiple wallets
  • Interaction with sanctioned or high-risk jurisdictions
  • Use of privacy-enhancing technologies (e.g., mixers, tumblers)

4.2 Screening Against Sanctions Lists

Users and transactions will be screened against global watchlists, including:

  • OFAC (U.S. Treasury Office of Foreign Assets Control) Sanctions List
  • UN Security Council Sanctions List
  • EU and UK Sanctions List
  • Financial Action Task Force (FATF) High-Risk Countries

BlockEstateDAO reserves the right to reject, block, or freeze transactions associated with sanctioned individuals, organizations, or jurisdictions.

5. Prohibited Transactions & Activities

Users are strictly prohibited from engaging in the following activities using BlockEstateDAO’s platform:

  • Money Laundering: Concealing the origin of illicit funds
  • Terrorist Financing: Providing financial support to terrorist organizations
  • Fraudulent Activities: Engaging in identity theft, false representations, or deceptive practices
  • Sanctions Evasion: Conducting transactions on behalf of sanctioned persons or entities
  • Dark Web Transactions: Using BlockEstateDAO’s ecosystem to facilitate illicit activities
  • Use of Privacy Coins or Mixers: Transacting using Monero (XMR), Tornado Cash, or similar anonymizing technologies

6. Reporting & Compliance Enforcement

6.1 Reporting Suspicious Activity

BlockEstateDAO may report suspicious activities to the relevant financial authorities, including but not limited to FinCEN (U.S.), FCA (UK), DGII (Dominican Republic), and Delaware Department of Justice (DOJ) for digital asset regulatory enforcement.

Users acknowledge that:

  • BlockEstateDAO has the right to file Suspicious Activity Reports (SARs) without notifying the User.
  • BlockEstateDAO may request additional information at any time to verify the legitimacy of transactions.
  • Failure to provide requested information may result in account suspension, transaction reversal, or expulsion from the DAO.

  • Freezing & Termination of Accounts

BlockEstateDAO reserves the right to freeze, suspend, or terminate a User’s access to DAO-related services if: 

  • The User fails KYC/AML verification 
  • The User engages in prohibited activities (as outlined in Section 5)
  • The User refuses to provide requested compliance documentation
  • The User’s transactions raise red flags in accordance with AML monitoring policies
  • BlockEstateDAO is required to take action under applicable laws or by order of a competent regulatory authority

  • Data Privacy & Retention

8.1 Data Protection Compliance BlockEstateDAO will handle all User data in compliance with: • General Data Protection Regulation (GDPR – EU) • California Consumer Privacy Act (CCPA – U.S.) • UK Data Protection Act 2018

8.2 Data Retention Period KYC data will be retained for a minimum of 5 years after a User ceases to participate in the DAO, or longer if required by applicable laws.

  • Governing Law & Jurisdiction

This Agreement shall be governed exclusively by the laws of the State of Delaware, United States.

Any disputes arising under this Agreement shall be resolved through arbitration or legal proceedings in the State of Delaware, in compliance with the Delaware Digital Asset Laws.

BlockEstateDAO does not submit to the jurisdiction of the United Kingdom or the Dominican Republic, except where explicitly required by local laws for regulatory compliance.

  • Acceptance & Compliance Certification

By signing below (or electronically accepting this Agreement), the User certifies compliance with BlockEstateDAO’s KYC/AML policies and acknowledges the DAO’s right to enforce this Agreement.

User Name: ___________________

User Wallet Address: ___________________

Date: ___________________