AML / KYC Policy

This Anti-Money-Laundering and Know-Your-Customer Policy ("Policy") describes how Halcyon One LLC, doing business as Halcera ("Halcera," "we"), verifies users, screens for prohibited persons and jurisdictions, and monitors for misuse. Our access model is vetted-by-design: no one obtains dashboard access automatically.

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1. Purpose and principles

Halcera is committed to preventing its Platform from being used for money laundering, terrorist financing, fraud, sanctions evasion, or other illicit activity. Our compliance approach rests on four principles: (1) verify before access — identity and eligibility are checked before any account is granted; (2) risk-based review — scrutiny scales with risk signals; (3) screen continuously — sanctions and prohibited-jurisdiction checks are applied at onboarding and on an ongoing basis; and (4) keep records — KYC and transaction records are retained as required by law.

2. Manual onboarding (the core control)

Access to Halcera is granted only after a human onboarding review. There is no auto-signup. The process is:

a. Application. The applicant completes a structured Request Access form capturing identity, contact, professional, use-case, and compliance information (see Section 3).

b. Verification of contact points. Email and phone are verified before the application can be submitted.

c. Human review. A member of the onboarding team reviews each application against the checks in Section 4, targeting a response within 24–72 hours.

d. Decision. The application is approved, returned for additional information, or declined. Approval is at our discretion.

e. First purchase. Access is unlocked only after the approved applicant completes their first credit pack purchase — at which point payment-side controls also apply.

We never auto-approve applications. Manual review is a deliberate, non-negotiable control.

3. Information collected (CIP)

As part of our Customer Identification Program, we collect and, where appropriate, verify:

• full legal name;
• date of birth;
• country of residence and tax residence;
• verified email and phone;
• professional context (role, company, company website, professional background);
• the digital properties the applicant intends to use the Platform for;
• stated use case and expected usage; and
• payment-method information through our payment processor.

We may request additional identity documentation (such as government-issued ID) where risk signals warrant Enhanced Due Diligence (Section 5).

4. Standard onboarding checks

For each application, the onboarding team assesses:

a. email and phone verification status;

b. plausibility and consistency of the stated identity, company, and use case;

c. screening of the applicant and, where relevant, associated names against applicable sanctions and watchlists (including US OFAC and other lists we are required to check);

d. the applicant's country against our restricted-jurisdiction list (Section 6);

e. presence of obvious red flags — disposable email domains, mismatched or contradictory data, refusal to verify, or use cases inconsistent with the Platform's purpose; and

f. alignment of the application with our Acceptable Use Policy.

5. Risk-based and Enhanced Due Diligence

Applications and accounts are assigned a risk level based on the factors above and on transaction behavior. Higher-risk cases trigger Enhanced Due Diligence, which may include requesting government-issued identification, proof of address, additional information about source of funds or business, or a verification call. We may decline or limit accounts where risk cannot be adequately mitigated.

6. Restricted and prohibited jurisdictions

We do not provide the Platform to persons located in, or resident in, jurisdictions subject to comprehensive sanctions, or to any person we are legally prohibited from dealing with. The restricted-jurisdiction list is maintained internally and updated as sanctions regimes change. Applications from restricted jurisdictions are declined.

7. Ongoing monitoring

After approval we monitor for:

a. sanctions-list changes affecting an existing user (periodic rescreening);

b. unusual transaction patterns relative to the user's stated profile, such as rapid escalation in purchase size or velocity inconsistent with the account history;

c. indicators of card testing, stolen-instrument use, or structuring; and

d. behavior inconsistent with the Acceptable Use Policy.

Where monitoring surfaces concerns, we may request information, suspend access, reverse or refund transactions, or terminate the account.

8. Transaction controls and payments

Payments are processed by regulated third-party payment processors, which apply their own fraud and AML controls. Halcera does not hold customer funds as a deposit-taking institution and does not operate credits as a transferable cash-equivalent (see Terms of Service Section 5). Credits are non-transferable between accounts, which removes a common laundering vector.

9. Suspicious activity and reporting

Where we identify activity we reasonably believe to be illicit, we will take appropriate action, which may include suspending the account, declining or reversing transactions, preserving records, and making any reports to authorities required by applicable law. We cooperate with lawful requests from competent authorities.

10. Recordkeeping

We retain customer identification information, onboarding decisions, and transaction records for the minimum periods required by applicable AML, tax, and accounting law, and longer where there is a legitimate or legal need. Records are stored securely with restricted access.

11. Governance

Responsibility for this Policy sits with Halcera management. The Policy is reviewed periodically and updated in response to regulatory change, new risk typologies, and operational experience. Staff involved in onboarding receive guidance on applying these controls consistently.

12. Contact

Compliance / onboarding queries: support@halcera.com Halcyon One LLC — Wyoming, United States