1. Purpose
Rush Hour P2P operates a risk-based AML program designed to prevent money laundering, terrorist financing, and sanctions evasion, consistent with FATF standards and the laws of [OPERATING JURISDICTIONS].
2. Identity verification
- All users must provide a government-issued photo ID and pass a liveness check before their first trade.
- Higher-tier users must provide proof of address and, in some cases, proof of source of funds.
3. Screening
- Every account is screened at onboarding and on an ongoing basis against OFAC, UN, EU, UK HMT, and applicable local sanctions lists.
- Politically Exposed Person (PEP) and adverse media screening are performed on the same schedule.
- On-chain address screening may be performed on deposits and withdrawals.
4. Tiered limits
Trading volume is capped by KYC tier. Higher tiers require additional verification. Current tier caps are shown in-app and may change based on risk assessment.
5. Suspicious activity
We are required to file Suspicious Activity Reports (SARs) or equivalent with the competent Financial Intelligence Unit where reporting thresholds are met. By law we may not tip off the subject of a report.
6. Restricted regions
The Service is not offered to users in Restricted Regions. See our Restricted Regions page.
7. Compliance officer
Our designated Money Laundering Reporting Officer (MLRO) is [MLRO NAME]. Compliance contact: [COMPLIANCE EMAIL].
8. Record keeping
Identity records, transaction data, and audit logs are retained for the period required by applicable law (typically 5–7 years after account closure).