1. Policy Statement & Purpose

Zakat Coin Inc. is committed to full compliance with the Bank Secrecy Act (BSA), USA PATRIOT Act, FinCEN regulations, and FATF recommendations. This program is designed to prevent money laundering, terrorist financing, and other financial crimes while ensuring transparency in charitable donations. Zakat Coin Inc. is registered with FinCEN as a Money Services Business (MSB), registration number 31000302240755, effective June 11, 2025.

2. Compliance Officer

Zakat Coin Inc. has appointed Lena Alwari-Erakat, Co-Founder and President, as the BSA/AML Compliance Officer. She is responsible for the day-to-day oversight of this program, including reporting, training, and ensuring compliance with applicable laws and regulations.

3. Customer Identification Program (CIP/KYC)

All customers acquiring tokens during the Donation Coin Offering (DCO) must complete KYC through Plaid and approved ID verification partners. Information collected includes name, date of birth, address, and identification number. Coming Soon: expanded KYC vendor coverage for additional jurisdictions.

4. Customer Due Diligence (CDD/EDD)

Standard due diligence is applied to all users. Enhanced Due Diligence (EDD) will be applied for higher-risk transactions, including large acquisitions and users from high-risk jurisdictions. Coming Soon: automated thresholds for EDD post-launch.

5. Sanctions / OFAC / PEP Screening

All customers are screened against OFAC, UN, and PEP lists. Screening occurs at onboarding via Plaid and compliance software integrations.

6. Transaction Monitoring

All token acquisitions and wallet flows are recorded on-chain and monitored. Alerts will be generated for unusual activity such as large acquisitions, multiple linked wallets, or geographic anomalies. Coming Soon: third-party blockchain analytics provider integration post-launch.

7. Suspicious Activity Reporting (SAR)

Suspicious transactions will be flagged and reported to FinCEN. Zakat Coin reserves the right to suspend customer accounts pending investigation.

8. Recordkeeping

All KYC, transaction, and SAR data is maintained for a minimum of 5 years in compliance with 31 CFR.

9. Employee Training

The Compliance Officer will provide annual AML training to employees. Expanded training programs will be developed as staffing grows.

10. Independent Testing / Audit

This AML program will be subject to annual independent review and audit. Currently overseen internally by the Compliance Officer; third-party audits will be engaged after DCO.