AML/KYC Policy

Anti-Money Laundering and Know Your Customer Policy — Last Updated: March, 2026

Northern Trust Digital is committed to complying with all applicable anti-money laundering (AML) and counter-terrorism financing laws, including the US Bank Secrecy Act (BSA) and regulations administered by FinCEN. We have implemented a risk-based AML program.

Customer Identification (KYC)

Before activating trading or accepting deposits, we require verification of your identity, including:

Government-issued photo ID
Proof of address
Additional information for enhanced due diligence (e.g., source of funds) if you are a high-risk user (e.g., from certain jurisdictions or high-volume trader).

We screen against sanctions lists and monitor for suspicious activity.

Ongoing Monitoring

We monitor transactions, including arbitrage trades and profit distributions, for unusual patterns. We may freeze accounts or report suspicious activity via Suspicious Activity Reports (SARs) to FinCEN as required.

Recordkeeping

We maintain records for the periods required by law.

Compliance Officer

We have designated a Compliance Officer responsible for our AML program.

If you have questions about our AML policy, contact compliance@northerntrustdigital.com. We may update this policy as required by law.