Customer Due Diligence (CDD)

MonkeyTilt employs a risk-based CDD approach to understand user interactions with its platform and establish a customer risk profile. This involves collecting both documentary and non-documentary information when opening an account, tailored to the type of account and services offered by MonkeyTilt. Different CDD standards apply to various accounts and services.

For example, users must complete MonkeyTilt's customer identification program (CIP), which includes:

Gathering basic information (e.g, full name, DOB, wallet address and email) during account setup via MonkeyTilt's user onboarding portal;
Continued monitoring risks associated with the cryptocurrency wallet funding the account;
Keeping records of user identification information, and updating intermittently; and
Checking if users are on any lists of known or suspected terrorists or terrorist organizations.

These steps are implemented through:

Identity, Age and Address Verification: A third-party service verifies the authenticity of identification and other KYC materials, ensuring users are permissible and not located in sanctioned or prohibited jurisdictions. It also checks global sanctions lists using onboarding information like wallet addresses.
Customer Information: MonkeyTilt collects information to confidently identify its users, in line with their risk profile. This may include wallet address, name, address, country, date of birth, or postal code. This information is gathered before issuing a MonkeyTilt funding address to users. Currently, MonkeyTilt does not serve non-natural persons and may rely on other institutions for some CIP elements.
Geo-blocking for Prohibited and Sanctioned Jurisdictions: Monkey Tilt requires client certifications for IP address-based geo-blocking to prevent offering services in countries where it's illegal or users are under U.S., EU, or other global sanctions.
Contractual Restrictions for Users from Prohibited Jurisdictions: Users are informed during onboarding about service restrictions in certain jurisdictions, based on Monkey Tilt's risk, fraud prevention, and AML policies.

Enhanced Due Diligence and Ongoing Monitoring

For example, users must complete MonkeyTilt's customer identification program (CIP), which includes:

Gathering basic information (e.g, full name, DOB, wallet address and email) during account setup via MonkeyTilt's user onboarding portal;
Continued monitoring risks associated with the cryptocurrency wallet funding the account;
Keeping records of user identification information, and updating intermittently; and
Checking if users are on any lists of known or suspected terrorists or terrorist organizations.

MonkeyTilt conducts regular monitoring to identify potential money laundering or terrorism financing activities. This involves using red flag indicators to detect suspicious behaviors, leading to enhanced due diligence if triggered. Enhanced KYC includes verifying:

Full legal name;
Residency or Citizenship;
Permanent address;
Identification number (taxpayer ID, passport number, alien ID card number, etc.);
Identification document;
If required, source of funds and wealth.

Third-party services are used for verification to establish the true identity of users with suspicious activities.

Acceptance Policy

MonkeyTilt will block users who

Fail to provide requested identification information;
Submit false identification documents;
Misrepresent their location;
Are from restricted or prohibited jurisdictions;
Are subject to U.S., EU, or other global sanctions or watch lists;
Have gambling addiction or mental health issues;
Have funds originating or exchanged in restricted jurisdictions.

MonkeyTilt reserves the right to block or suspend users for other reasons at its discretion.

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