Rollick is committed to preventing money laundering, terrorist financing, and other financial crimes. This policy outlines our Customer Identification Program and due diligence procedures in compliance with the Bank Secrecy Act and FinCEN regulations.

All users must provide the following information during registration:

• Full legal name
• Date of birth
• Residential address
• Government-issued ID number

Rollick verifies identity against authoritative databases before account activation. We reserve the right to request additional documentation at any time.

Tier 1 (Basic): Email and date of birth verification. Spending limit: $500/month. Withdrawal limit: $200/month.

Tier 2 (Standard): Government-issued photo ID and proof of address. Spending limit: $5,000/month. Withdrawal limit: $2,500/month.

Tier 3 (Enhanced): Additional identity verification and source of funds documentation. Unlimited spending. Withdrawal limit: $25,000/month.

Tier upgrades require document submission and typically process within 24-48 hours.

Enhanced due diligence procedures are triggered for:

• Transactions over $10,000 (single or cumulative within 24 hours)
• Users from high-risk jurisdictions
• Unusual transaction patterns (rapid deposits/withdrawals, structuring)
• Politically exposed persons (PEPs)
• Users flagged by our automated monitoring systems

Rollick employs continuous monitoring systems to detect and prevent financial crimes. We monitor for:

• Rapid cycling of funds (deposit followed by minimal activity followed by withdrawal)
• Multiple accounts linked to the same identity or payment method
• Transactions inconsistent with user profile
• Use of anonymizing services or VPNs to circumvent geographic restrictions

Suspicious activity is reported to FinCEN via Suspicious Activity Reports (SARs).

All users are screened against the following sanctions lists at registration and periodically thereafter:

• OFAC Specially Designated Nationals (SDN) list
• EU sanctions lists
• UN sanctions lists

Matches result in immediate account freeze and regulatory reporting.

Transaction records are retained for 7 years per BSA requirements. KYC documentation is retained for 5 years after account closure.

All staff with access to user data or financial systems complete annual AML/KYC training. Training covers identification of suspicious activity, regulatory obligations, and internal escalation procedures.

Rollick files the following reports as required by applicable law:

• Currency Transaction Reports (CTRs) for transactions over $10,000
• Suspicious Activity Reports (SARs) for suspected financial crimes

Reports are filed confidentially; users are not notified of SAR filings. Tipping off is prohibited under federal law.

Users must provide accurate information, update their details promptly, and cooperate with verification requests. Failure to comply may result in account restriction or termination.

For questions about this policy, please contact us:

• KYC Questions: [email protected]
• Regulatory Inquiries: [email protected]
• Mail: Rollick Inc., 1209 Orange Street, Wilmington, DE 19801