Legal

AML / KYC Policy

Last updated: April 23, 2026

1. Purpose

ETHIO AMERICAN LLC ("Company") maintains an Anti-Money Laundering ("AML") and Know Your Customer ("KYC") program designed to comply with applicable U.S. financial regulations, including the Bank Secrecy Act (BSA), regulations of the Financial Crimes Enforcement Network (FinCEN), and Washington State money transmission requirements.

2. Registrations & licensing

"AWASHDIRECT LLC is registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN)."

3. Customer identification (KYC)

Identity verification is required after registration and before account activation. We collect and verify, at a minimum, the customer's full legal name, date of birth, residential address, and a government-issued identification number, along with supporting documentation. Additional information may be required for enhanced due diligence.

4. Customer due diligence (CDD) & enhanced due diligence (EDD)

We apply risk-based customer due diligence to understand the nature and purpose of the customer relationship and to develop a customer risk profile. Enhanced due diligence is applied to higher-risk customers and transactions, and may include additional documentation, source-of-funds review and ongoing monitoring.

5. Sanctions screening

We screen customers and transactions against applicable sanctions lists, including those administered by the U.S. Office of Foreign Assets Control (OFAC). Transactions involving sanctioned persons or jurisdictions are blocked or rejected as required by law.

6. Transaction monitoring & reporting

We monitor transactions for activity that may be indicative of money laundering, terrorist financing, fraud or other illicit conduct. Where required, we file Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs) and other reports with FinCEN and applicable authorities.

7. Recordkeeping

We retain customer identification records, transaction records and related documentation for the periods required by applicable law and regulation.

8. Compliance officer

The Company has appointed a Compliance Officer responsible for the day-to-day operation of the AML/KYC program. The Compliance Officer can be reached at admin@ethioamericanllc.com.

9. Training

Personnel involved in the operation of the Services receive AML/KYC training appropriate to their role and responsibilities.

10. Independent review

The AML/KYC program is subject to periodic independent review consistent with regulatory expectations.

11. Cooperation with authorities

We cooperate with law enforcement and regulatory authorities in connection with investigations and lawful requests, in line with applicable legal requirements.

We operate in accordance with applicable U.S. financial regulations, including AML and KYC requirements. This policy summary is provided for transparency and does not constitute legal advice.