Purpose
INCEPTO applies a risk-based compliance framework designed to reduce risks relating to money laundering, terrorist financing, sanctions violations, fraud, identity misuse, prohibited jurisdictions, illegal proceeds, market abuse, and misuse of digital asset opportunities. Controls may vary by user, project, jurisdiction, feature, risk profile, and legal requirement.
BVI AML and VASP Compliance Context
As a British Virgin Islands company operating in a digital asset environment, Dotstart Technologies Ltd may take account of BVI AML, counter-terrorist financing, sanctions, beneficial ownership, recordkeeping, and virtual asset regulatory expectations where applicable. The platform may apply controls even where a particular activity is not treated as a regulated virtual asset service, and may suspend or restructure features if counsel determines that BVI VASP registration, additional AML controls, or other approvals are required.
Identity Information
We may request full legal name, date of birth, residential address, phone number, email, country of residence, citizenship, tax country, government identification document, document number, document issue date, proof of address, selfie or liveness information where enabled, and other data necessary to establish identity.
Entity Information
For entities, we may request formation documents, registered address, business address, ownership structure, beneficial owner information, director or manager details, authority documents, tax forms, source-of-funds evidence, source-of-wealth evidence, investment mandate, and information about controllers or authorized representatives.
Verification Levels
An incomplete profile may be treated as not verified. A complete profile without approved documents may be treated as partially verified. A complete profile with approved documents may be treated as fully verified. Partially verified users may receive access to certain project workflows at administrator discretion, but verification status never guarantees allocation, payment access, or token delivery.
Sanctions Screening
We may screen users, beneficial owners, representatives, wallet addresses, payment details, locations, and related parties against sanctions lists, restricted jurisdiction lists, law enforcement notices, blockchain analytics signals, project restrictions, and internal risk rules. We may deny, suspend, or terminate access where a sanctions or restricted-party concern exists.
Restricted Jurisdictions
Certain jurisdictions may be restricted by law, sanctions, project policy, platform policy, banking partners, payment providers, or compliance judgment. We may block access based on IP address, residence, citizenship, location, tax residence, wallet activity, or other indicators. Attempts to evade geographic controls may result in account closure.
Source of Funds and Wealth
We may request information or documents about employment, income, business activity, savings, investment proceeds, trading profits, inheritance, sale of assets, company distributions, loans, or other sources of funds and wealth. We may reject access where funds appear inconsistent, unsupported, high risk, or potentially unlawful.
Wallet and Transaction Review
We may review wallet addresses, transaction hashes, payment networks, blockchain activity, exposure to mixers, sanctioned addresses, darknet markets, scams, hacks, high-risk exchanges, stolen funds, ransomware, or other risk indicators. Wallet review may occur before or after payment submission.
Enhanced Due Diligence
We may require enhanced review for higher-risk users, larger allocations, entity accounts, PEPs, high-risk jurisdictions, unusual wallet activity, inconsistent data, suspicious documents, source-of-funds concerns, or project-specific requirements. Enhanced review may include additional documents, explanations, video checks, or delayed processing.
Ongoing Monitoring
KYC and AML review is not a one-time event. We may monitor accounts, applications, payment orders, support messages, wallet changes, status changes, IP patterns, and transaction activity over time. We may re-verify information or request updates before allowing continued access.
Suspicious Activity
Where we identify suspicious activity, we may restrict features, freeze review, decline applications, cancel payment orders, preserve records, request additional information, report to competent authorities or compliance partners, and avoid disclosing detailed reasons where doing so could compromise security or legal obligations.
No Duty to Explain Decisions
For AML, sanctions, fraud-prevention, security, legal, project, or risk-management reasons, we may not provide detailed explanations for rejection, suspension, termination, waitlisting, payment hold, or enhanced due diligence requests.
Recordkeeping
We may retain KYC, AML, sanctions, application, wallet, payment, support, and admin decision records for legally required periods or for a reasonable period needed to evidence compliance, prevent fraud, defend claims, assist investigations, and protect platform integrity. Where BVI law, AML expectations, sanctions compliance, regulator inquiry, law enforcement request, project dispute, or litigation hold requires longer retention, records may be retained after account closure.
User Obligations
You must provide truthful, complete, and current information; not use nominees or false identities; not conceal beneficial ownership; not use unlawful proceeds; not transact for sanctioned persons; not evade controls; and promptly respond to compliance requests. Failure to comply may result in rejection, suspension, termination, or reporting.