Anti-Money Laundering & Counter-Terrorist Financing Policy
1. Policy Principles
ANCORA implements a privacy-preserving AML/CFT framework that maintains user privacy while enabling optional compliance for regulated service providers. The core protocol does not implement surveillance or tracking – compliance tools are optional layers implemented by service providers.
2. Core Protocol Privacy Protection
The ANCORA core protocol natively:
Does not collect or store user personal information
Does not track or surveil user transactions
Does not implement blacklisting or censorship at protocol level
Provides full transactional privacy for all users by default
All AML/CFT compliance is implemented at the service provider layer (exchanges, wallets, custodians), not at the base protocol layer.
3. Regulated Service Provider Requirements
All regulated service providers (exchanges, custodians, payment processors) using ANCORA must implement:
3.1 Know Your Customer (KYC)
Customer identity verification for all users
Enhanced due diligence for high-risk customers
Politically Exposed Person (PEP) screening
Sanctions list screening (OFAC, UN, EU)
3.2 Transaction Monitoring
Real-time transaction monitoring for suspicious activity
Risk-based transaction limits
Travel rule compliance for transfers between VASPs
Pattern analysis for money laundering indicators
3.3 Reporting Requirements
Suspicious Activity Report (SAR) filing with relevant authorities
Large transaction reporting as required by local regulation
Record keeping for minimum 5 years
Regulatory reporting as required by jurisdiction
4. Privacy-Preserving Compliance Tools
ANCORA provides optional zero-knowledge compliance tools that enable verification without exposing user data:
Zero-knowledge proof of compliance without revealing transaction details
Selective disclosure for regulatory reporting
Privacy-preserving sanctions screening
Encrypted audit trails for regulators
These tools are optional and used only by regulated service providers. Core protocol users are not required to use any compliance tools.
5. Network Sanctions Policy
While the core protocol does not implement censorship, the ANCORA governance system maintains a global sanctions address list for entities on official UN, EU, and OFAC sanctions lists:
Service providers are required to block transactions to/from sanctioned addresses
Governance may vote to add addresses to the public sanctions list
No protocol-level blocking – enforcement is at service provider layer
All additions require 67% governance approval and full evidence disclosure
6. Compliance Oversight
All service providers are independently responsible for local regulatory compliance
ANCORA provides compliance tooling but does not act as a regulator
Governance may revoke ecosystem grants for non-compliant service providers
Annual compliance audit for all grant recipients