Compliance Program — NEROVIX LLC

Overview

NEROVIX LLC is committed to conducting its digital asset activities in full compliance with applicable United States laws and regulations, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, regulations administered by the Financial Crimes Enforcement Network (FinCEN), and sanctions programs administered by the Office of Foreign Assets Control (OFAC).

To that end, the company maintains a written Anti-Money Laundering (AML) program reasonably designed to prevent the company from being used to facilitate money laundering, terrorist financing, or other illicit activity.

Pillars of Our AML Program

1. Designated Compliance Officer

A designated compliance officer is responsible for the day-to-day administration of the AML program, monitoring regulatory developments, and ensuring policies and procedures remain current and effective.

2. Customer Identification & Due Diligence (KYC/CDD)

Identity verification of customers prior to establishing a business relationship;
Risk-based customer due diligence, with enhanced due diligence (EDD) for higher-risk customers and activity;
Screening of customers against OFAC sanctions lists and other applicable watchlists;
Prohibition of anonymous accounts and relationships with shell institutions.

3. Transaction Monitoring & Reporting

Ongoing monitoring of transactions, including on-chain analytics for digital asset activity;
Identification, investigation, and escalation of unusual or suspicious activity;
Filing of Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) with FinCEN where required by law.

4. Record-Keeping

The company maintains records of customer identification, transactions, and compliance activities for no less than five years, in accordance with BSA record-keeping requirements.

5. Training

Personnel receive AML training appropriate to their roles upon onboarding and on an ongoing basis, covering red flags, escalation procedures, and regulatory obligations.

6. Independent Review

The AML program is subject to periodic independent review to assess its adequacy and effectiveness, with findings reported to management and remediated promptly.

Regulatory Registrations & Licensing

NEROVIX LLC evaluates its activities against federal and state regulatory frameworks on an ongoing basis. Where the company's activities constitute those of a money services business (MSB) under FinCEN regulations (31 CFR § 1010.100(ff)), the company registers with FinCEN and complies with all obligations applicable to MSBs, and obtains any required state money transmitter licenses before engaging in covered activity in a given state.

Sanctions Compliance

NEROVIX LLC does not conduct business with individuals or entities on the OFAC Specially Designated Nationals (SDN) list, or with persons located in comprehensively sanctioned jurisdictions. Screening is performed at onboarding and on an ongoing basis.

Data Security & Governance

Compliance depends on the integrity of the systems behind it. Our security program includes:

Access control: role-based access with least-privilege defaults; administrative actions require multi-party approval;
Key management: hardware-backed key storage, segregation of duties for asset movements, and documented key ceremonies;
Encryption: data encrypted in transit (TLS) and at rest;
Logging & monitoring: tamper-evident audit logs of system and administrative activity, retained alongside BSA records;
Incident response: a documented response plan covering containment, notification, and post-incident review.

Frequently Asked Questions

Is NEROVIX LLC a registered money services business?

NEROVIX evaluates its activities against FinCEN's MSB definitions on an ongoing basis and completes federal registration and applicable state licensing before engaging in any covered activity. For the current status of our registrations, contact [email protected] — we will respond with specifics and supporting documentation where appropriate.

How do you verify customers?

Through a risk-based KYC/KYB process: government-ID verification for individuals, formation and ownership documentation for entities, sanctions and watchlist screening for both, and enhanced due diligence where risk indicators are present.

Do you serve customers outside the United States?

Where we do, we first assess the regulatory requirements of the customer's jurisdiction. We do not serve persons in comprehensively sanctioned jurisdictions or persons subject to OFAC sanctions under any circumstances.

How do law enforcement and regulators reach you?

Via [email protected] or by mail to our Denver principal office. Please include your agency, a reference number, and the legal basis of the request so we can route and prioritize it correctly.

Contact

Questions regarding our compliance program may be directed to [email protected].

This page is a summary of NEROVIX LLC's compliance framework and is provided for informational purposes. It does not constitute legal advice and does not create any rights in favor of any third party.