AML and Sanctions Policy

1. Our commitment

VIVI is committed to preventing the use of its Services for money laundering, terrorist financing, proliferation financing, fraud and sanctions evasion. We design our controls with reference to the UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism, the Financial Action Task Force (FATF) recommendations on virtual assets, and applicable sanctions regimes.

2. Controls

• Geographic restriction of interactive features for restricted jurisdictions, enforced at the network edge.
• Self-certification of eligibility before using the Services, with a record of the confirmation.
• Screening of wallet addresses against sanctions lists and blockchain-analytics risk indicators, where appropriate and lawful.
• The right to refuse, restrict or block any wallet or user without notice where we suspect prohibited activity.
• Risk-based customer due diligence, including identity verification and source-of-funds checks, if we introduce regulated products or if required by law or by a regulator.
• Record keeping and retention in line with applicable law.

3. Reporting and cooperation

Where required, we will report suspicious activity to the competent authority and cooperate with lawful requests from regulators and law enforcement. We may be prohibited from telling you that we have made a report.

4. Prohibited activity

• Transacting with, or on behalf of, a sanctioned person, entity or jurisdiction.
• Using mixers or other tools to obscure the origin of funds in connection with the Services.
• Structuring transactions to avoid controls.

5. Reporting a concern

Contact our compliance team at compliance@vivi.example. Reports can be made in confidence.