AML and CTF compliance statement

Effective Date: January 1, 2025

Last Updated: April 25, 2025

Version: 1.0

This document is not a substitute for professional legal or compliance advice. AML obligations vary significantly by jurisdiction and business model.

1. Our Commitment to Compliance

DLIA INC is committed to preventing the Platform from being used for money laundering, terrorist financing, or other financial crime. We maintain controls proportionate to the risks associated with our marketplace operations.

DLIA does not itself hold, lend, or invest funds. Payments flow through regulated third-party payment processors such as Stripe. Even so, we recognise that marketplaces can be exploited by bad actors and we maintain active controls to mitigate this risk.

2. Applicable Legal Framework

Jurisdiction	Legislation
United Kingdom	Proceeds of Crime Act 2002, Terrorism Act 2000, and the 2017 Money Laundering Regulations
European Union	EU 6th Anti-Money Laundering Directive
United States	Bank Secrecy Act, USA PATRIOT Act, and FinCEN guidance for online marketplaces
Other jurisdictions	Applicable local AML and CTF legislation
Global	FATF recommendations

3. Know Your Customer

3.1 Seller Verification

All sellers on DLIA must complete KYC before they may list bookings or receive payouts. This includes:

Submission of a government-issued photo ID
Manual review by DLIA staff
Recording of verification status and timestamp

3.2 Buyer Verification

Buyers are not currently subject to mandatory KYC unless a transaction exceeds a defined threshold, the activity triggers a risk flag, or applicable law requires it.

3.3 Enhanced Due Diligence

In higher-risk cases, including high-value transactions, higher-risk jurisdictions, or politically exposed persons, we may request additional documentation or source of funds information.

4. Suspicious Activity Monitoring

DLIA monitors Platform activity for indicators of suspicious or unusual behaviour, including:

Unusually high transaction volumes from a single account
Multiple accounts sending funds to the same recipient
Listings priced significantly above or below market value
Buyers purchasing and immediately re-listing bookings without obvious purpose
Payment methods inconsistent with the user profile
IP addresses associated with sanctions exposure or known fraud patterns
Rapid account creation followed by high-volume activity

5. Transaction Monitoring and Limits

5.1 Transaction Thresholds

DLIA may apply enhanced scrutiny or temporarily hold transactions that:

Exceed $1,000 in a single transaction
Exceed $5,000 in aggregate within a 30-day rolling period per account

These thresholds may change as our risk assessment framework evolves.

5.2 Payout Holds

DLIA reserves the right to hold seller payouts pending additional checks carried out in connection with AML obligations.

6. Sanctions Screening

DLIA screens users against sanctions lists including:

HM Treasury Consolidated Sanctions List
EU Consolidated Sanctions List
OFAC Specially Designated Nationals List
UN Security Council Consolidated Sanctions List
Additional OFAC and FinCEN watchlists where relevant

Accounts matching or closely matching a sanctioned individual or entity may be suspended immediately and referred to the appropriate authority.

7. Politically Exposed Persons

DLIA may apply enhanced due diligence to politically exposed persons and their close associates, including additional documentation and source of funds verification.

8. Reporting Suspicious Activity

8.1 Internal Reporting

DLIA's designated Money Laundering Reporting Officer is responsible for receiving and evaluating internal reports of suspicious activity.

MLRO Contact: Compliance Officer
Email: info@dlia.app

8.2 External Reporting

Where a Suspicious Activity Report is warranted, it may be filed with the appropriate authority, including the UK National Crime Agency or the US Financial Crimes Enforcement Network.

8.3 Tipping Off

DLIA staff are prohibited from tipping off a subject of a suspicious activity report or investigation, as that may be a criminal offence.

9. Record Keeping

Record Type	Retention Period
KYC documents and verification records	Minimum 5 years from the transaction date or end of relationship
Transaction records	Minimum 5 to 7 years depending on jurisdiction
SAR filings and supporting documents	As required by law
AML risk assessments	Minimum 5 years from creation

All records are stored securely and access is restricted to authorised personnel.

10. Staff Training and Awareness

Relevant DLIA personnel receive:

AML and CTF awareness training on joining
Regular refresher training at least annually
Briefings on updates to applicable AML law and FATF guidance

11. Risk Assessment

DLIA maintains a business-wide AML risk assessment that is reviewed at least annually and updated when significant changes occur to the business, geographic reach, or regulatory environment.

12. User Cooperation

By using DLIA, you agree to:

Provide accurate identity information and documentation when requested
Cooperate with enhanced due diligence requests
Not use the Platform to launder money, finance terrorism, or engage in financial crime

Failure to cooperate may result in account suspension, payout withholding, and reporting to relevant authorities.

13. External Reporting for Users

If you suspect money laundering or financial crime involving another user, report it to info@dlia.app with the subject AML/Fraud Report. You may also report directly to your national law enforcement or financial intelligence unit.

14. Review of This Policy

This AML and CTF Compliance Statement is reviewed and updated at least annually, or whenever there are changes to applicable law, DLIA's business model, geographic reach, or underlying risk assessment.

15. Contact

Email: info@dlia.app
Address: 131 Continental Dr, Suite 305, Newark, DE 19713, US
URL: https://dlia.app/compliance