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IC Capital Seed Round / Token Participation

AML/KYC Policy

Version: Draft for legal review | Last updated: May 19, 2026

Participation in the seed round may be available only to users who have passed KYC/AML, sanctions screening, wallet ownership verification, and accepted the documents.

1. Purpose

This policy sets baseline rules for identification, verification, sanctions screening, source-of-funds review, wallet ownership verification, whitelist, and ongoing monitoring for IC Capital Seed Round / Token Participation.

2. Mandatory Checks

3. Whitelist

If a whitelist model is implemented, Tokens may be available only for wallet addresses whitelisted by the Company after KYC/AML. The Company may update, remove, freeze, or refuse whitelist status if legal, AML, sanctions, fraud, or wallet-control risk arises.

4. Secondary Transfers

Secondary transfer may be prohibited or permitted only between whitelisted / KYC-approved participants. Transfers to unidentified addresses, liquidity pools, bridges, mixers, sanctioned addresses, or non-approved wallets may not be recognized for conversion, refund, reporting, or any other rights.

5. Right to Refuse, Return, or Block

The Company may refuse participation, reject acceptance, return a contribution, block a wallet, freeze or disregard a balance, request additional documents, or terminate interaction if required for KYC/AML, sanctions, legal, tax, regulatory, or operational reasons.

6. Prohibited Participants

Participation is prohibited for sanctioned persons, persons from prohibited jurisdictions, persons unable to prove lawful source of funds, persons suspected of fraud, money laundering, terrorism financing, circumvention, or undisclosed nominee arrangements.

7. Repeated KYC/AML

The Company may require repeated KYC/AML before transfer, refund, conversion, snapshot, material update, or upon a risk trigger. Failure to pass repeated KYC/AML may result in rights not being recognized until the risk is resolved.

8. Data and Confidentiality

KYC/AML data is processed under the Privacy Policy and may be shared with KYC providers, wallet screening services, banks, exchanges, legal/compliance advisers, authorities, or courts where necessary for a lawful purpose.

9. Contact

AML/KYC requests should be sent to [CONTACT_EMAIL].