KYC & AML Verification Policy

Danny Clans Media Limited ("Company") is committed to preventing fraud, money laundering, terrorist financing, sanctions violations and other unlawful activity. This policy applies to every user of the customer dashboard at dashboard.dannyclans.systems ("Dashboard") and of DC Assistant, our assistant on Telegram, including every member of a customer's team, and describes the checks we may carry out. It is referenced by section 14 of the Dashboard Terms of Service.

1. Purpose

We may verify the identity, business activities, ownership, team members, payment methods and source of funds of any user at any time — before opening an account, before crediting a deposit, before paying a refund, or during ongoing use. We may deny, suspend, restrict or terminate services where satisfactory verification cannot be completed.

2. A Risk-Based Approach

The checks we carry out depend on the risk: who the customer is, where they are, what they advertise, how much money moves and how. A small advertiser in a low-risk market paying by bank transfer from their own business account will be asked for less than a business in a higher-risk vertical moving large sums in USDT. We review a customer's risk when something material changes.

3. Verification Requirements

We may require any user to provide:

The person operating the account

• Government-issued photo identification.
• Proof of address.
• Confirmation of the phone number and email on the account.

The business

• Certificate of incorporation or business registration.
• Proof of business address.
• Ownership structure and the identity of beneficial owners.
• Identification of the authorised representative.
• Tax registration documents.

Team members

• Confirmation that each person on the team works for, or is engaged by, the business, and — for Admins, and for the person who links DC Assistant — the same identification as the person operating the account.

Business registration is asked for on every account because Advertising Platforms require it for applications; the rest is asked for when the value or the pattern of activity warrants it.

A copy of an identity document is collected only to verify the person named on it, is never used as an account identifier, and is held as the Privacy Policy describes, in line with the Privacy Commissioner's Code of Practice on the Identity Card Number and other Personal Identifiers.

4. Payment Method Verification

We may ask you to show that a payment method is yours: that a bank account is in your business's name, that a card is held by an authorised representative, or that you control the address a USDT payment came from. Refunds are paid only to a verified method in the name of the business, as the Refund and Withdrawal Policy describes. Third-party payments — money sent by someone other than the business — may be refused or returned.

5. Source of Funds

We may ask where a payment came from — a bank statement, an invoice, a contract — and may hold a deposit until we are satisfied. A deposit whose origin cannot be established may be returned by the method it arrived by, less any charges we incurred.

6. Sanctions and Politically Exposed Persons

We do not deal with persons or businesses subject to sanctions administered by the United Nations, the Hong Kong SAR Government, the United States, the European Union or the United Kingdom, or located in a jurisdiction we do not serve. We may check names and payments against sanctions lists and, for USDT, use blockchain analytics, ourselves or through our payment providers. Any action taken on a match is decided by a member of our staff, and you may ask us to reconsider.

If a customer, a beneficial owner or a team member is, or is closely connected to, a person holding a prominent public function, we may ask for more information about the business and the source of its funds before continuing.

7. Higher-Risk Advertising

Advertising for financial services, cryptocurrency, gambling, medicines, health products and supplements, dating and other regulated or sensitive categories carries more risk for us and for the Advertising Platforms. For these we may ask for the licence, registration or platform approval the advertising requires, check the landing pages, and apply lower limits or closer monitoring until we are satisfied.

8. Ongoing Monitoring

We may review accounts and transactions for activity that is inconsistent with the business as described to us, for deposits and withdrawals that appear to move money rather than pay for advertising, for sudden changes of team members, of the linked Telegram account or of refund details, and for patterns associated with fraud or abuse. Requests made through DC Assistant are monitored in the same way as those made in the Dashboard. We may ask for further verification at any point.

9. Suspension of Services

Where verification is incomplete, refused or unsatisfactory, or where monitoring raises a concern we cannot resolve, we may suspend the account, remove a team member's access, disconnect DC Assistant, hold deposits and refunds, and disable advertising accounts until the matter is resolved. A hold is not a forfeiture: money that is yours is returned when the matter is resolved, less anything you owe us.

10. Reporting Obligations

We may report suspicious activity to the Joint Financial Intelligence Unit of Hong Kong or other competent authorities as the law requires, and may be prohibited from telling you that we have done so.

11. Record Retention

Verification documents and the results of checks are kept for as long as the Privacy Policy describes — at least seven years for anything connected to a financial transaction, as the law requires — and are then deleted.

12. Responsibility and Review

A senior member of our staff is responsible for this policy, for decisions on difficult cases, and for any report to the authorities. Staff who handle customers' money are trained on it. We review the policy at least once a year and whenever the law, our payment providers or the Advertising Platforms require.

13. No Liability

We are not liable for any loss, delay or inconvenience caused by verification, a hold, a report, or a refusal to deal, made in good faith under this policy.