Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy
 Effective Date: April 1, 2025

1. Introduction

Siriux Foundation (“Siriux”, “we”, “our”, or “us”) is committed to promoting the highest standards of ethical conduct and compliance with applicable laws and regulations aimed at preventing the use of its infrastructure and ecosystem for money laundering, terrorism financing, and other financial crimes. Although Siriux operates a decentralized, non-custodial protocol and does not hold user funds, we voluntarily adopt and implement measures that support global anti-money laundering (AML) and counter-terrorism financing (CTF) efforts.

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2. Scope of this Policy

This AML/CTF Policy applies to:

• The Siriux Foundation;
  
  

• Contributors and affiliates acting on behalf of the Foundation;
  
  

• Third-party service providers and vendors who may have access to relevant data;
  
  

• Partners and counterparties engaging with the Siriux ecosystem.
  
  

While Siriux does not provide custodial services or process financial transactions directly, it acknowledges the importance of implementing proactive strategies to mitigate misuse of its open infrastructure.

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3. Regulatory Background

This Policy aligns with international AML/CTF standards, including but not limited to:

• Financial Action Task Force (FATF) Recommendations;
  
  

• EU AML Directives (AMLD5, AMLD6);
  
  

• Swiss Anti-Money Laundering Act (AMLA);
  
  

• United Nations Sanctions Regulations;
  
  

• U.S. Bank Secrecy Act (BSA) and OFAC requirements (where applicable).
  
  

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4. Non-Custodial Nature of the Protocol

The Siriux protocol is decentralized and operates via smart contracts deployed on public blockchains. The Foundation does not:

• Provide custodial wallets or escrow services;
  
  

• Collect, hold, or manage users’ assets;
  
  

• Verify or monitor financial transactions conducted through the network.
  
  

Given this structure, Siriux is not classified as a Virtual Asset Service Provider (VASP) under most regulatory definitions. However, we actively monitor and mitigate risks.

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5. Risk-Based Approach

Siriux adopts a risk-based approach (RBA) to AML/CTF, which includes:

• Assessing the risks associated with protocol misuse;
  
  

• Implementing technical measures to detect and respond to suspicious activity;
  
  

• Engaging with analytics partners to trace illicit wallet activity;
  
  

• Restricting engagement with high-risk jurisdictions.
  
  

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6. Sanctions and Restricted Jurisdictions

Siriux prohibits any interaction with the protocol or affiliated services by individuals, wallets, or entities that are:

• Subject to economic sanctions (OFAC, EU, UK, UN);
  
  

• Located in comprehensively sanctioned jurisdictions (e.g., North Korea, Iran, Syria);
  
  

• Attempting to circumvent restrictions via VPNs or obfuscation techniques.
  
  

We implement blocklists and geofencing technologies where technically feasible to reduce exposure to sanctioned entities.

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7. Monitoring and Surveillance Measures

Although Siriux does not conduct traditional Know Your Customer (KYC) procedures due to its non-custodial nature, we implement the following:

• Use of on-chain analytics tools (e.g., Chainalysis, TRM Labs) to monitor transaction flows;
  
  

• Detection of high-risk wallet addresses and automated alerts;
  
  

• Monitoring developer repositories and integrations for red flags;
  
  

• Internal incident reporting and escalation procedures.
  
  

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8. Reporting Suspicious Activity

If suspicious activity is detected, Siriux may:

• Limit or block front-end access to involved wallet addresses;
  
  

• Document the incident for internal records;
  
  

• Cooperate with law enforcement or competent authorities where legally obligated;
  
  

• Disclose metadata or logs to the extent permissible under applicable law.
  
  

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9. Third-Party Service Providers

Vendors and third-party service providers engaged by Siriux must:

• Adhere to AML/CTF obligations under their respective jurisdictions;
  
  

• Maintain appropriate internal compliance procedures;
  
  

• Notify Siriux of any detected misuse or abuse relating to our infrastructure.
  
  

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10. Governance and Oversight

Siriux Foundation maintains internal oversight mechanisms to:

• Review and update this Policy annually or as needed;
  
  

• Conduct risk assessments relevant to changes in the ecosystem;
  
  

• Provide training and awareness to contributors and team members;
  
  

• Evaluate partnerships and integrations based on AML/CTF risks.
  
  

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11. Limitations and Disclaimers

Due to the open-source and permissionless nature of the Siriux protocol:

• We cannot prevent all illicit use of public smart contracts;
  
  

• Blockchain data is immutable and, once recorded, cannot be modified;
  
  

• Our tools and procedures are aimed at reducing—not eliminating—risk exposure.
  
  

We make no representations that our measures fully comply with every jurisdiction’s AML laws but affirm our good faith efforts to support regulatory integrity.

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12. Contact

To report suspicious activity or raise concerns regarding this Policy, please contact the Siriux Compliance Team:
  📧 legal@siriux.ai