1. Scope and Commitment
Si Va LLC, a Wyoming limited liability company ("SIVA", "we", "us"), adopts this policy to prevent, detect, and report activity related to money laundering and the financing of terrorism (AML/CFT), in accordance with the U.S. Bank Secrecy Act (BSA) and the regulations and guidance issued by FinCEN, OFAC, and other competent authorities.
Regulatory Status
Si Va LLC maintains an anti-money-laundering (AML) and Know-Your-Customer (KYC) program designed to comply with the applicable requirements of the U.S. Bank Secrecy Act (BSA) and the regulations administered by FinCEN and OFAC. This includes identity verification, sanctions screening, transaction monitoring, and reporting of suspicious activity as required by applicable law.
2. Roles and Responsibilities
- Management — approves and oversees this policy.
- Compliance Officer — implements, monitors, and enforces the program.
- Employees and third parties — must comply fully and report any irregularity.
3. Customer Identification & Due Diligence (KYC)
Every user completes the Customer Identification Program (KYC) before operating. Users are screened against restrictive and sanctions lists (OFAC, UN, EU, and others), and the source of funds is verified. There is no exception to this verification for operations of any amount.
4. Registration and Nature of Users
The platform registers natural persons under their full legal name. For legal entities, both of the following are required:
- Individual registration of the representative as a natural person (individual KYC).
- Validation of the entity through business KYC (beneficial ownership, formation documents).
5. KYC Verification Levels
Verification requirements scale with transaction size and risk:
- Level 1 — low-value single transactions, with basic identity documentation.
- Level 2 — standard identity verification for ongoing use.
- Level 3 — higher-value activity requiring a declaration of the source of funds.
- Level 4 — large transactions requiring enhanced due diligence and documentary support.
- Level 5 — business entities (business KYC).
- Level 6 — biometric validation for high-risk cases.
6. Transaction Monitoring (Automated + Human)
Transaction data is analyzed to detect atypical patterns. Every alert is reviewed by a human verification performed by the Compliance Officer before any action is taken.
7. Enhanced Due Diligence & High-Risk Cases
Politically Exposed Persons (PEPs) and users connected to high-risk jurisdictions are subject to enhanced monitoring. Any match against international sanctions lists results in denial of service. Larger transactions require documentation of the source of funds and explicit Compliance Officer approval.
8. Reporting to Authorities
To the extent Si Va LLC is subject to such requirements under the BSA and applicable FinCEN regulations, it files the applicable reports with FinCEN, including Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) for reportable cash transactions (generally those exceeding USD $10,000).
9. Recordkeeping
All KYC records, monitoring data, forms, and reports are retained for the period required by applicable law (at least five years under the BSA) in a secure, auditable digital format.
10. Review and Update
This policy is reviewed and updated at least once a year, or whenever regulations, the detected risks, or the instructions of the competent authorities change.
11. Consequences of Non-Compliance
Violations of this policy may result in suspension or closure of the account, with the return of funds following the applicable compliance and administrative procedures.
12. Contact
Compliance inquiries can be sent to info@sivausa.io.