Purpose and Scope

Magius maintains this Know Your Customer (KYC) Policy to prevent money laundering, terrorist financing, and other financial crimes. The policy applies to all Magius customers and users accessing Magius services, including those utilizing cryptocurrency wallets, and covers onboarding, identity verification, ongoing monitoring, reporting, and record-keeping in accordance with applicable law.

Governance and Compliance Oversight

The Board of Magius has designated a Chief Compliance Officer (CCO) who is responsible for implementing this policy, maintaining independent reporting to the Board, and coordinating with competent authorities as required by law. The CCO has authority to initiate investigations, supervise suspicious activity reporting, and issue internal guidance to ensure ongoing compliance.

Roles and Responsibilities

• All Magius personnel must comply with this policy and report any suspected money laundering, terrorist financing, or sanctions concerns to the CCO without delay.
• Senior management must ensure appropriate training, risk-based controls, and periodic reviews of policy effectiveness.

Know Your Customer and Verification

• We apply a risk-based Customer Due Diligence (CDD) framework. Verification requirements scale with identified risk and transactional exposure.
• On onboarding, Magius collects identifying information sufficient to establish the customer’s identity and location, including full name, date of birth, residential address, country of residence, and a valid email address; where applicable, a wallet address associated with cryptocurrency activity will also be captured.
• Documentation typically required includes government-issued photo identification (e.g., passport or national ID) and proof of address (dated within the last three months). For higher-risk customers or activities, Magius may require a source-of-funds determination supported by documentation such as payslips, bank statements, or investment statements.
• Age verification confirms that the customer is at least eighteen (18) years old before full access to services is granted.
• Where available, Magius may use approved third-party services to verify the accuracy of provided information and to corroborate identity data against official records.
• Geographic screening and declarations: onboarding requires that the customer is not located in Prohibited Jurisdictions and is not personally subject to Sanctioned Jurisdictions. IP address-based geolocation and other technologically reasonable controls will be used to enforce these restrictions.

Sanctions, Prohibited Jurisdictions, and Geo-Blocking

Magius blocks access to its services for individuals located in or acting on behalf of Prohibited Jurisdictions or subject to global sanctions. Location information, device data, and IP geolocation are used to determine jurisdiction. Users must not attempt to circumvent geographic controls. Ongoing screening against sanctions lists is performed and updated as required by law and licensing obligations.

Ongoing Monitoring and Red Flags

Magius conducts ongoing monitoring of customer activity to detect unusual patterns, large or unusual transactions, rapid changes in behavior, or other indicators of ML/TF risk or sanctions exposure. The monitoring combines automated surveillance with manual review. When red flags are identified, Magius may require additional information, impose withdrawal holds, or suspend or limit access to accounts or funds, including refusal to process withdrawals to high‑risk addresses or counterparties where supported by risk scoring.

Enhanced Due Diligence

When risk indicators trigger enhanced scrutiny, Magius will implement Enhanced Due Diligence (EDD). EDD may require customers to provide additional information and documentation, including:

• Full legal name and date of birth;
• Country of citizenship and permanent residential address;
• Government-issued identification documents (valid and unexpired) and a biometric verification where applicable;
• Source of funds and source of wealth documentation (e.g., payslips, bank statements, inheritance or investment records).
• Documentation review may involve third-party verifiers to corroborate provided information.

Failure to provide satisfactory evidence may result in restrictions, temporary suspension, or account termination.

Blocking and Restriction

Magius reserves the right to block or suspend accounts for—among other grounds—the failure to provide requested KYC information, use of false information, attempts to conceal identity or location, involvement with Prohibited or Sanctioned Jurisdictions, involvement with sanctioned entities, or other actions that Magius reasonably regards as increasing risk. Blocking or restriction may be temporary or permanent in Magius’ sole discretion.

Reporting and Cooperation with Authorities

Where legally required or appropriate, Magius will report identified sanctions breaches or suspicious activity to the competent authorities and, as applicable, to the relevant financial intelligence unit. Magius cooperates with regulators and law enforcement in accordance with applicable law and licensing requirements.

Record-Keeping and Data Retention

Magius retains customer identification records for a minimum of six (6) years after the termination of the customer relationship and transaction records for at least ten (10) years after execution or account closure. Records are stored securely with appropriate encryption and access controls in line with applicable data protection laws.

Data Security and Privacy

Magius implements robust technical and organizational measures to protect personal data against loss, theft, or unauthorized disclosure. Access to personal data is restricted to authorized personnel, and data may be disclosed to authorities or third-party service providers solely to fulfill AML obligations or with explicit user consent, and in accordance with applicable data protection laws.

Communication, Rights, and Contact

Customers will receive clear instructions regarding the KYC process and any additional requests. Magius provides channels for questions and complaints and undertakes timely responses. For questions about this policy, please contact Magius compliance team at [email protected].