KYC / AML
Policy

At DIGITAL PROTOTYPE LTD, we engineer secure, sovereign architectures. While we firmly believe in the cryptographic privacy of end-users, we enforce absolute transparency regarding the corporate entities we do business with.

This Know Your Customer (KYC) and Anti-Money Laundering (AML) Protocol is designed to ensure strict compliance with the European Union's AML Directives (AMLD) and the Austrian Financial Market Authority (FMA) guidelines. We categorically refuse to engage in commercial transactions that obscure the origin of capital or the identity of the Ultimate Beneficial Owners (UBO).

Prior to the countersignature of any Master Services Agreement (MSA) or the acceptance of a project mobilization fee, the Client must submit to our deterministic corporate verification process. We require the following immutable documentation:

• Corporate Identity: A highly verifiable Certificate of Incorporation (or equivalent commercial register extract) issued within the last 3 months.
• Tax Governance: A valid European VAT number or equivalent international corporate tax identification number.
• Beneficial Ownership: A formal declaration identifying the Ultimate Beneficial Owners (UBO) who hold 25% or more of the corporate shares or voting rights.
• Executive Authority: Verifiable identification (e.g., Passport, National ID) of the executive directors or authorized signatories executing the MSA.

We enforce strict origin-of-funds policies to mathematically eliminate the risk of money laundering or terrorist financing through our engineering services:

• Account Parity: All incoming financial settlements (SEPA, SWIFT, or authorized digital payments) must originate deterministically from a corporate bank account held in the exact name of the verified Client entity.
• No Third-Party Settlements: We categorically reject payments routed through unverified third-party shell companies, personal accounts of employees, or unauthorized payment brokers.
• Cryptographic Assets: If payment via cryptographic assets (e.g., stablecoins) is authorized in the MSA, it will only be accepted via regulated institutional custody providers where strict chain-analysis and origin verification have already been performed. We do not accept direct transfers from unverified, non-custodial wallets.

DIGITAL PROTOTYPE LTD algorithmically screens all prospective clients, their directors, and UBOs against global sanction databases. We enforce strict adherence to:

• The consolidated list of persons, groups, and entities subject to EU financial sanctions.
• The Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list.
• United Nations Security Council Consolidated Lists.

We will not deploy infrastructure, blueprint architecture, or accept capital from entities domiciled in comprehensively sanctioned jurisdictions or from individuals flagged on the aforementioned global watchlists.

As a compliant European corporate entity, we maintain a legal obligation to monitor for and report financial anomalies. If we detect obfuscated payment routing, deliberate falsification of corporate identity documents, or unexplained structural changes to funding sources, we reserve the right to immediately suspend all SLA retainers and report the suspicious telemetry to the Austrian Financial Intelligence Unit (FIU) without prior notification to the Client.

All corporate identification documents collected during the KYC onboarding process are stored within an encrypted, Sovereign Perimeter Control environment. These records are retained for exactly five (5) years following the termination of the business relationship, strictly to satisfy EU AML audit requirements, after which they are cryptographically destroyed.

Last Compiled and Verified: October 2024 (Version 1.5.0)