This AML & Sanctions Compliance Policy describes the risk-based controls used by Enbytes LLC ("The Fivve," "we," "us," or "our") in connection with thefivve.com and related The Fivve application interfaces.
1. Purpose
The Fivve is a first-party NFT digital collectibles project offering primary NFT sales and related holder perks. This policy is intended to help prevent misuse of the Services for unlawful activity, including money laundering, fraud, sanctions evasion, theft, terrorist financing, or other prohibited conduct.
2. Scope of Services
Our Services currently do not include:
- custodial wallet services;
- exchange services;
- user-to-user transfers through our platform;
- stored-value accounts;
- remittance or money transmission through our platform;
- fiat-to-crypto conversion by us on a customer's behalf.
Payments may be facilitated by third-party payment partners and processors.
3. Prohibited Users and Activity
You may not use the Services if you are:
- a person or entity on a sanctions or blocked-person list applicable to us;
- located in, organized in, or ordinarily resident in a jurisdiction we restrict due to sanctions, legal risk, processor restrictions, or internal compliance controls;
- acting on behalf of a sanctioned, blocked, or prohibited person;
- attempting to conceal identity, location, source of funds, beneficial ownership, or transaction purpose for unlawful reasons.
You may not use the Services to engage in:
- fraud;
- chargeback abuse;
- identity misuse;
- card testing;
- sanctions evasion;
- wallet obfuscation for unlawful purposes;
- use of stolen payment methods;
- proceeds of crime;
- suspicious or manipulative transaction patterns;
- any activity that violates applicable law.
4. Geographic Restrictions
We may block or restrict access from certain jurisdictions, including jurisdictions subject to sanctions, embargoes, heightened legal restrictions, heightened fraud risk, or payment-partner restrictions.
The list of restricted jurisdictions may change at any time without notice.
5. Risk-Based Controls
We use a risk-based compliance approach that may include:
- suspicious activity review;
- wallet screening and blockchain-risk review;
- transaction pattern monitoring;
- IP and device checks;
- billing and order consistency review;
- manual review of certain purchases or support interactions;
- recordkeeping for purchases and compliance events.
6. KYC and Sanctions Screening
As of the effective date of this policy, The Fivve does not currently conduct formal KYC for all users and does not currently conduct full sanctions screening for every user as a standard onboarding step.
However, we may, in our sole discretion or through our service providers:
- request additional information or documentation;
- review transactions or wallets;
- delay, reject, cancel, or refund a transaction;
- suspend or terminate access;
- cooperate with law enforcement, regulators, payment partners, and service providers where appropriate or legally required.
7. Wallet Screening
If you provide or connect a wallet address, we may review or screen that wallet address and related transaction activity for risk indicators, including links to known exploits, hacks, sanctions exposure, mixers, dark-market activity, fraud typologies, or other red flags, to the extent reasonably available through our tools or service providers.
8. Recordkeeping
We may retain records relating to purchases, support contacts, billing data, wallet data you provide, compliance reviews, and related transaction metadata for as long as reasonably necessary for legal, operational, fraud-prevention, accounting, and compliance purposes.
9. Cooperation with Service Providers and Authorities
We may share information with payment processors, hosting providers, analytics providers, advisors, law enforcement, regulators, or other authorities when reasonably necessary to:
- investigate suspected fraud or unlawful conduct;
- comply with applicable law, court orders, subpoenas, or lawful requests;
- enforce our Terms of Service and internal policies;
- protect the Services, our users, and our business.
10. Right to Refuse or Cancel Transactions
We reserve the right to refuse, delay, limit, review, suspend, cancel, or reverse access to the Services or a purchase request if we believe, in our sole discretion, that the activity poses fraud, sanctions, legal, operational, or reputational risk.
This may occur even if a transaction has been initiated but not completed.
11. User Cooperation
You agree to provide accurate information and to cooperate reasonably with any review we conduct. Failure to cooperate may result in cancellation of a transaction, denial of access, or closure of your access to the Services.
12. No Circumvention
You may not attempt to bypass our compliance controls by using:
- VPNs or proxies for unlawful concealment;
- false billing or contact information;
- nominee accounts or straw purchasers;
- third-party payment methods without authorization;
- misleading wallet activity.
13. Reporting Concerns
If you believe the Services are being misused, or if you have questions about this policy, contact:
14. Changes to This Policy
We may update this AML & Sanctions Compliance Policy at any time by posting the revised version on the Services and updating the "Last Updated" date.