Anti-Money Laundering (AML) Policy

11. Introduction

FollowTurk LLC ("FollowTurk", "we", "us") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines the measures we implement to prevent and detect money laundering, terrorist financing, and other financial crimes through our platform.

This AML Policy applies to all users, transactions, and activities conducted through the FollowTurk platform, and is enforced in accordance with applicable laws and regulations, including but not limited to the Bank Secrecy Act (BSA), USA PATRIOT Act, EU Anti-Money Laundering Directives, and relevant international standards set by the Financial Action Task Force (FATF).

22. Know Your Customer (KYC) Procedures

FollowTurk implements a risk-based Know Your Customer (KYC) program to verify the identity of its users. Our KYC procedures include:

• Identity Verification: Users may be required to submit a valid government-issued photo ID (passport, national ID card, or driver's license), a selfie holding the ID document, and proof of address when prompted by our system.
• Payment Method Verification: Users may be required to verify ownership of payment methods used on the platform, including credit/debit card photographs and bank receipt verification.
• Enhanced Due Diligence (EDD): Additional verification steps are applied for high-value transactions, users from high-risk jurisdictions, or accounts exhibiting unusual activity patterns.
• Ongoing Monitoring: User accounts and transactions are continuously monitored for suspicious activity throughout the business relationship.

Users who fail to complete KYC verification within the specified timeframe (24 hours) will have their accounts suspended, and any pending deposits will be automatically refunded to the original payment method.

33. Transaction Monitoring

FollowTurk employs automated and manual transaction monitoring systems to detect and flag suspicious activities. Our monitoring measures include:

• Velocity Checks: Automated detection of rapid or repeated transactions from the same user, IP address, or device fingerprint that may indicate fraudulent activity.
• Device Fingerprinting: Dual-layer device identification technology to detect and prevent account creation fraud, multi-accounting, and unauthorized access attempts.
• IP Address Analysis: Monitoring of IP addresses for suspicious patterns, including VPN/proxy usage, geographic inconsistencies, and known malicious IP ranges.
• Card Fingerprinting: Tracking of payment card usage across accounts to identify shared or stolen payment instruments.
• Risk-Based Deposit Holds: New accounts are subject to a 24-hour deposit holding period; accounts flagged as suspicious are subject to a 72-hour holding period. Trusted users with verified history receive immediate deposit processing.

44. Risk Assessment & Classification

FollowTurk maintains a risk-based approach to customer classification. Users are assigned a trust level based on their account history and behavior:

• New Users: All new accounts are treated with heightened scrutiny. Deposits are held for a cooling period, and KYC may be triggered by suspicious patterns.
• Trusted Users: Accounts with 7+ days of activity and at least one successful verified deposit are classified as trusted, receiving expedited processing.
• Suspicious Users: Accounts flagged by our automated systems or manual review are subject to enhanced monitoring, extended deposit holds, and mandatory KYC verification.

55. 3D Secure & Payment Security

All credit and debit card transactions processed through FollowTurk are subject to mandatory 3D Secure (3DS) authentication. This additional layer of security:

• Verifies that the cardholder is the legitimate owner of the payment method
• Reduces the risk of unauthorized transactions and fraud
• Provides an additional authentication step through the cardholder's bank
• Supports chargeback prevention by confirming cardholder intent

66. Prohibited Activities

The following activities are strictly prohibited on the FollowTurk platform and will result in immediate account termination and reporting to relevant authorities:

• Using the platform to launder money or finance terrorism
• Using stolen credit cards, bank accounts, or other fraudulent payment methods
• Structuring transactions to avoid reporting thresholds or KYC triggers
• Creating multiple accounts to circumvent security measures or bans
• Initiating fraudulent chargebacks or payment disputes
• Using the platform on behalf of a sanctioned individual or entity

77. Suspicious Activity Reporting

FollowTurk is committed to cooperating with law enforcement and regulatory authorities. When suspicious activity is detected, we take the following actions:

• Immediate suspension of the affected account(s)
• Internal investigation by our compliance team
• Filing of Suspicious Activity Reports (SARs) with relevant authorities when required by law
• Preservation of all relevant transaction records and evidence
• Full cooperation with law enforcement investigations, including providing records and documentation upon valid legal request

88. Record Keeping

FollowTurk maintains comprehensive records of all transactions, KYC documents, and account activities in accordance with applicable record retention requirements:

• Transaction records are retained for a minimum of 5 years
• KYC documents are securely stored for 90 days after verification (up to 1 year for flagged accounts)
• Account activity logs, including IP addresses, device fingerprints, and login history, are retained for audit and investigation purposes
• All records are stored securely with access restricted to authorized compliance personnel

99. Sanctions Compliance

FollowTurk does not knowingly conduct business with individuals or entities that are subject to economic sanctions imposed by the United States (OFAC), the European Union, the United Nations, or other applicable jurisdictions. We reserve the right to restrict or block access from sanctioned countries and territories.

1010. Employee Training & Compliance

FollowTurk ensures that all relevant personnel receive regular training on AML/CTF policies, procedures, and their obligations under applicable law. Our compliance program is reviewed and updated periodically to reflect changes in regulations and emerging risks.

1111. Policy Updates

This AML Policy is reviewed and updated periodically to ensure compliance with evolving legal requirements and industry best practices. Users will be notified of material changes through our website. Continued use of the platform after any updates constitutes acceptance of the revised policy.

1212. Contact Information

If you have questions about this AML Policy, wish to report suspicious activity, or need to contact our compliance team, please reach out to us:

• FollowTurk LTD — Company No. 17160355, 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, England & Wales
• FollowTurk LLC — 169 Madison Ave STE 11534 Unit 301, New York, NY 10016, Delaware, USA
• Email: [email protected]

Last updated: April 2026