1. POLICY OBJECTIVE

This policy is designed to:

• Prevent misuse of the ecosystem for illegal activities
• Align with global AML and CFT principles
• Protect the community and ecosystem integrity
• Support lawful and responsible participation

Trust Bitcoin balances decentralization with risk-based compliance.

2. NATURE OF TRUST BITCOIN

Trust Bitcoin is a decentralized, community-governed Layer-1 blockchain ecosystem.

Important clarifications:

• Trust Bitcoin is not a financial institution
• Trust Bitcoin is not a bank or payment service provider
• Trust Bitcoin is not a custodial service
• Trust Bitcoin does not hold user funds

Participation in the blockchain network itself does not automatically require KYC.

3. RISK-BASED COMPLIANCE APPROACH

Trust Bitcoin follows a risk-based approach to KYC, AML, and CFT.

This means:

• KYC is applied only when required
• Not all users are subject to identity verification
• Compliance requirements depend on the service or utility involved

This approach aligns with international best practices.

4. WHEN KYC MAY BE REQUIRED

KYC verification may be required in specific cases, including but not limited to:

• Participation in international travel utilities
• Access to regulated services or features
• Use of fiat-linked or regulated products (e.g., future stablecoins)
• Legal or regulatory requirements
• Fraud prevention or risk management

Early blockchain participation and wallet usage may not require KYC.

5. KYC INFORMATION (IF APPLICABLE)

When KYC is required, users may be asked to provide:

• Government-issued identification
• Proof of identity or address
• Date of birth
• Nationality
• Additional information required by law

KYC data is collected only for compliance purposes.

6. AML & CFT COMMITMENT

AML Statement

Trust Bitcoin does not custody user funds.

Users interact directly with blockchain wallets.

Operational services provided by TBC Digital Labs FZCO comply with UAE regulations.

Treasury entities may conduct compliance checks where required.

Trust Bitcoin is committed to preventing:

• Money laundering
• Terrorist financing
• Sanctions violations
• Fraud or illicit financial activity

• Monitor compliance-related activity
• Cooperate with lawful authorities
• Restrict access to services when necessary

7. SANCTIONS & RESTRICTED JURISDICTIONS

Trust Bitcoin may restrict access to certain services for users located in jurisdictions subject to:

• International sanctions
• High AML/CFT risk classifications
• Legal or regulatory prohibitions

Users are responsible for complying with local laws.

8. NON-CUSTODIAL DESIGN & LIMITATIONS

Because Trust Bitcoin is non-custodial:

• Trust Bitcoin does not control user wallets
• Trust Bitcoin cannot freeze or seize on-chain assets
• Blockchain transactions are irreversible

Compliance measures apply only to services and utilities, not to the blockchain protocol itself.

9. THIRD-PARTY KYC PROVIDERS

When KYC is required:

• Verification may be conducted through trusted third-party providers
• Third-party providers follow their own privacy and compliance standards
• Trust Bitcoin does not misuse or sell KYC data

Data handling follows the Privacy Policy.

10. DATA PROTECTION & PRIVACY

• KYC data is handled securely
• Access is limited to authorized personnel or providers
• Data is retained only as long as legally required
• Data is not used for marketing purposes

Users retain rights under applicable data protection laws.

11. FAILURE OR REFUSAL TO COMPLETE KYC

If KYC is required and not completed:

• Access to specific services may be restricted
• Participation in certain utilities may be denied
• Blockchain access itself remains unaffected

No penalties are imposed for refusal beyond service limitations.

12. REPORTING & SUSPICIOUS ACTIVITY

Trust Bitcoin may:

• Investigate suspicious activity related to services
• Report activity when legally required
• Take reasonable steps to protect the ecosystem

Trust Bitcoin does not engage in unlawful surveillance.

13. POLICY UPDATES

This policy may be updated periodically to reflect:

• Regulatory developments
• Ecosystem changes
• Risk assessment outcomes

Updates will be published on official Trust Bitcoin channels.

14. USER ACKNOWLEDGEMENT

By using Trust Bitcoin services where KYC is required, users acknowledge that:

• Compliance checks may be mandatory
• Participation is voluntary
• Failure to comply may limit access to certain utilities