Anti-Money Laundering (AML) Policy

Purpose

Crowder Inc. (“Crowderbloom,” “we,” “us,” or “our”) is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy sets forth our principles and procedures to ensure compliance with applicable U.S. and international AML regulations.

Scope

This AML Policy applies to:

• All users of the Crowderbloom platform (creators and backers).
• All employees, contractors, and partners of Crowder Inc.
• All fiat and cryptocurrency transactions conducted on the platform.

Regulatory Framework

Crowder Inc. complies with:

• The Bank Secrecy Act (BSA) and USA PATRIOT Act (U.S.).
• Financial Crimes Enforcement Network (FinCEN) regulations.
• Applicable guidance from the Financial Action Task Force (FATF).
• Relevant state and international AML obligations.

Know Your Customer (KYC)

We require identity verification (KYC) for certain activities, including:

• Campaign creators launching projects.
• Backers making significant contributions above regulatory thresholds.
• Users requesting withdrawals.

Verification may include:

• Government-issued ID (passport, driver’s license, etc.).
• Proof of address (utility bill, bank statement).
• Date of birth and contact details.

Crowderbloom may use third-party providers to perform KYC checks.

Risk-Based Approach

We employ a risk-based approach to AML compliance:

• Low Risk: Small, routine pledges from verified sources.
• Medium Risk: Large pledges, unusual activity, or cross-border transactions.
• High Risk: Anonymous crypto wallets, politically exposed persons (PEPs), or users from high-risk jurisdictions.

Enhanced Due Diligence (EDD) is conducted for higher-risk cases.

Monitoring & Reporting

We continuously monitor transactions to identify suspicious activity, including:

• Structuring (breaking transactions to avoid reporting thresholds).
• Sudden large contributions or withdrawals.
• Use of mixers/tumblers to obscure crypto transactions.
• Contributions from sanctioned countries or blacklisted addresses.

Suspicious activity may be reported to FinCEN or other relevant authorities via Suspicious Activity Reports (SARs).

Recordkeeping

We maintain records for at least five (5) years, including:

• User identification data.
• Transaction histories (fiat and crypto).
• AML investigation and reporting records.

Employee Training

All Crowder Inc. employees handling user data or financial transactions receive AML training, including:

• Identifying suspicious activity.
• Understanding reporting obligations.
• Staying updated on regulatory changes.

Cryptocurrency-Specific Measures

Recognizing the risks of cryptocurrency transactions, Crowderbloom employs:

• Blockchain analytics tools to track wallet activity.
• Screening of wallet addresses against global sanction and watchlists.
• Restrictions on privacy coins or high-risk tokens, where required by law.

User Responsibilities

By using our platform, you agree to:

• Provide accurate and truthful information during KYC.
• Not engage in money laundering, fraud, or illegal financial activities.
• Cooperate with any AML-related requests or investigations.

Failure to comply may result in account suspension, fund freezing, or reporting to authorities.

Enforcement & Penalties

Crowder Inc. reserves the right to:

• Deny service to non-compliant users.
• Freeze or return suspicious funds.
• Terminate accounts engaged in prohibited activity.

Policy Updates

This AML Policy may be updated periodically to reflect regulatory changes or platform enhancements. Updates will be published on our website with a revised effective date.

Contact Information

For AML-related inquiries, contact us:

CROWDER INC
5323 Millenia Lakes Blvd #702
Orlando, FL 32839
United States
Email: info@crowderbloom.com