AML/KYC Policy

Last Updated: December 2025

1. Our Commitment

OpenHouse Technologies LTD is committed to preventing money laundering, terrorist financing, and other financial crimes. We comply with:

  • The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)

  • The Proceeds of Crime Act 2002

  • The Terrorism Act 2000

  • Financial Action Task Force (FATF) recommendations

  • FCA guidance on cryptoassets and financial crime

2. Customer Due Diligence (CDD)

2.1 When Verification is Required

All users must complete identity verification before:

  • Purchasing property tokens

  • Claiming rental distributions

  • Withdrawing funds from the Platform

  • Making transactions above applicable thresholds

2.2 Standard Verification

We collect and verify the following information:

Personal Information:

  • Full legal name

  • Date of birth

  • Residential address

  • Nationality

Identity Documents (one of):

  • Valid passport

  • National identity card

  • Driving licence

Proof of Address (one of):

  • Bank statement (dated within 3 months)

  • Utility bill (dated within 3 months)

  • Government correspondence

2.3 Enhanced Due Diligence (EDD)

Additional verification is required for:

  • High-value transactions (thresholds vary)

  • Politically Exposed Persons (PEPs)

  • Customers from higher-risk jurisdictions

  • Complex or unusual transaction patterns

  • Source of funds verification

3. Verification Process

Identity verification is conducted through our partner Persona, a regulated identity verification provider. The process typically involves:

  1. Submitting identity documents

  2. Taking a selfie for biometric matching

  3. Automated document and identity checks

  4. Manual review where required

Verification is usually completed within minutes but may take up to 48 hours for manual review cases.

4. Ongoing Monitoring

We continuously monitor for:

  • Suspicious transaction patterns

  • Changes in customer risk profile

  • Sanctions list matches

  • Unusual activity or behaviour

  • Negative news or adverse media

5. Sanctions Screening

All users are screened against:

  • UK HM Treasury sanctions lists

  • EU consolidated sanctions list

  • UN Security Council sanctions list

  • OFAC (US) sanctions list

  • Other relevant sanctions databases

Screening is performed at onboarding and on an ongoing basis.

6. Suspicious Activity Reporting

We are legally required to report suspicious activities to the National Crime Agency (NCA) via Suspicious Activity Reports (SARs).

Important: We cannot inform you if a report has been made about your account. This is known as "tipping off" and is a criminal offence.

7. Record Keeping

We retain all CDD records and transaction data for a minimum of 7 years after the business relationship ends, as required by law.

8. Your Obligations

As a user of OpenHouse, you must:

  • Provide accurate and truthful information

  • Update us promptly of any changes to your details

  • Not use the Platform for any illegal purposes

  • Cooperate with verification requests

  • Not attempt to circumvent our controls

Failure to comply may result in account suspension or termination.

9. Restricted Activities

The following activities are prohibited:

  • Money laundering or terrorist financing

  • Sanctions evasion

  • Tax evasion

  • Fraud or market manipulation

  • Using false or stolen identities

  • Structuring transactions to avoid reporting thresholds

10. Training and Governance

Our staff receive regular training on:

  • Identifying suspicious activity

  • CDD procedures

  • Sanctions compliance

  • Reporting obligations

We maintain a designated Money Laundering Reporting Officer (MLRO) responsible for oversight of our AML programme.

11. Contact

For questions about our AML/KYC procedures:

  • Email: legal@openhouse.finance

  • Address: 106 Flat 6, Lower Road, Hullbridge, Hockley, England, SS5 6DD

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