Compliance · Public Policy

AML / KYC / KYA
Policy

Azomland operates financial infrastructure for autonomous AI agents. This document describes our Anti-Money Laundering, Know Your Customer, and Know Your Agent protocols.

Last updated: September 2026 v1.1
01

Our compliance model

Azomland is financial infrastructure, a risk and identity layer that connects autonomous AI agents to regulated financial services. We partner with infrastructure providers for account, card, billing, subscription, and tax handling where available.

Under our delegated liability model, every agent account is guaranteed by a verified human or legal entity we call the Operator. The Operator assumes legal and financial responsibility for all actions their agent takes within the Azomland system.

AI Agent
The beneficiary. Operates autonomously within declared parameters.
Operator
KYC-verified human or company. Legal guarantor. Declares collateral.
Azomland
KYA™ risk layer. Program manager. Does not hold funds directly.
Regulated Partners
Eligible partners provide account, card, payment, or wallet infrastructure where available.
+
Billing Layer
Billing, subscriptions, tax compliance, and revenue collection where available.
02

Know Your Customer (KYC)

Before any agent account is activated, the Operator must complete identity verification. Accounts cannot be activated, and no card or wallet is issued, until Operator KYC is verified.

What we collect from Operators

  • Individuals: government-issued photo ID, proof of address, and declared source of funds.
  • Companies: incorporation documents, registered address, beneficial owner details, and authorized representative ID.
  • All Operators: sanctions, PEP, and adverse media screening where available.

Enhanced Due Diligence (EDD)

Operators from high-risk jurisdictions, politically exposed persons, or high-risk business models undergo enhanced due diligence before activation.

Ongoing monitoring

Operator status may be re-screened. Significant changes in transaction behavior may trigger alerts or documentation requests.

03

Know Your Agent™ (KYA)

KYA™ is Azomland proprietary scoring protocol. We score agents across six dimensions before granting access to financial capabilities. Closed-source agents do not qualify.

I · Framework

The architecture the agent runs on: PersonnnOS, OpenClaw, Hermes, LangChain, CrewAI, Codex. What weighs is the framework’s maturity, the real control it gives the operator, and its security record. Not the logo.

II · Code Health

We audit the public repo. Commit history, open issues, dependency vulnerabilities, loop-safety patterns and test coverage all factor into the score.

III · Business

What does the agent sell? Which markets does it operate in? Revenue history, product clarity, and addressable scope define credit eligibility.

IV · Operator

The human or entity guaranteeing the agent. KYC/KYB verified. Their financial standing, history, and declared collateral directly affect the agent's tier.

V · Jurisdictions

Countries the agent operates in, the regulatory environment, and transaction currency mix determine compliance overhead and tier ceiling.

VI · Track Record

Transaction behavior over time. Chargeback ratio, spending predictability, and anomaly incidents build (or destroy) the agent's standing in our system.

Score tiers and access levels

  • Sovereign (85 · 100): credit access, custom limits, USDC support, and dedicated compliance review where available.
  • Partner (75 · 84): expanded card access, USDC wallet support, multi-currency controls, and sub-accounts where available.
  • Node (60 · 74): entry-level virtual card access, USD balance support, ACH where available, and revenue collection.
  • Rejected (<60): no account issued. Operator is notified with the score and primary reason.

Every KYA decision is logged with a score breakdown. Rejected operators may request a review in writing to [email protected].

04

Anti-Money Laundering (AML)

Azomland maintains AML controls aligned with applicable partner, jurisdictional, and risk-based requirements.

Transaction monitoring

Agent transactions are monitored for anomalies, including activity inconsistent with declared business purpose, unusual geography, rapid accumulation of funds, or structuring behavior.

Suspicious Activity Reporting

Suspicious activity may be escalated to relevant partners or authorities where required. We do not notify account holders when prohibited by law.

Record keeping

KYC documents, transaction records, and compliance decisions may be retained as required by applicable law, partner requirements, and internal policy.

05

Restricted jurisdictions

Azomland does not provide services to individuals, companies, or agents with primary operations in restricted jurisdictions. Operators and agent operating countries are screened during review.

Completely restricted: no service

High-risk or comprehensively sanctioned jurisdictions are not eligible.

IranNorth Korea (DPRK)MyanmarCubaSyriaRussiaBelarusUkraineVenezuelaZimbabwe

Enhanced Due Diligence required

Jurisdictions under increased monitoring may require enhanced KYC and manual review before activation.

AngolaBoliviaBosnia and HerzegovinaBulgariaCameroonCôte d'IvoireDR CongoHaitiIraqKenyaKuwaitLaosLebanonMonacoNepalPapua New GuineaSouth SudanVietnamVirgin Islands (UK)Yemen

The enhanced due diligence list mirrors the FATF list of jurisdictions under increased monitoring as of the 17-19 June 2026 plenary, and is reviewed after each plenary. Grey-list status informs a risk-based assessment; it is not an automatic rejection. Providing false jurisdictional information is grounds for immediate termination and may be reported.

06

Prohibited activities

Azomland runs on licensed payment infrastructure. The restrictions below are inherited from the acquiring, issuing and money-movement partners we operate on, and they are cumulative: an activity refused by any one of our rails is refused by Azomland.

These restrictions apply to the agent, to the operator who guarantees it, and to the underlying business, regardless of whether the activity is legal in the jurisdiction where the operator is based. A local licence does not override a rail-level prohibition.

Illegal and controlled goods

  • Controlled substances, pharmaceuticals and paraphernalia without proper licensing
  • Cannabis, CBD and derivatives, including where locally legal
  • Weapons, arms dealing, ammunition, explosives and fireworks
  • Poisonous or hazardous materials without regulatory clearance
  • Endangered species, protected wildlife and derived products
  • Human remains or body parts

Exploitation and violence

  • Human trafficking, prostitution, escort services and mail-order brides
  • Child exploitation material
  • Hate groups and material promoting violence, intolerance or racial hatred
  • Terrorism support or financing

Fraud and deception

  • Pyramid schemes, Ponzi schemes and multilevel marketing
  • Counterfeit goods and intellectual property infringement
  • Credit repair, debt settlement and predatory lending
  • Payday lending and unregulated consumer lending
  • Miracle cures, unsubstantiated remedies and pseudo-pharmaceuticals
  • Sale of email or direct-marketing lists enabling unsolicited contact

Cybercrime and illicit data

  • Darknet marketplaces, ransomware and hacking-for-hire
  • Espionage equipment, signal jammers and blockers
  • Tools, guides or hardware to circumvent access controls on software, devices or networks
  • Cyberlocking and distribution of illegal or protected digital content
  • Data brokerage involving unauthorised personal data

Opaque financial structures

  • Shell banks and financial institutions without physical presence or purpose
  • Nested banking and nested payment processing
  • Unlicensed money service businesses
  • Unlicensed providers of licensed activities, including illegal crypto sales
  • Current or prior involvement with bearer shares

Restricted categories

  • Adult content, adult services and related classifieds
  • Political campaign fundraising and donation platforms
  • Unlicensed gambling and betting
  • Unlicensed auction sites and pawn shops
  • ATM operators
  • Foreign governments, state-owned enterprises, missions, embassies and consulates
  • Psychic and similar services

Accounts found operating in these categories are closed, funds are held pending review, and the case is reported where reporting obligations apply.

07

Activities requiring enhanced review

The following are not prohibited, but they are never approved on the standard path. They require evidence of licensing where licensing applies, proof of regulatory compliance, and documented internal controls before any limit is raised.

Money service businesses and remittance Licence in every operating jurisdiction, plus AML programme documentation
Crypto platforms and exchanges Registration where required, travel-rule handling and source-of-funds controls
Charities and NGOs Registration, governance and beneficiary transparency
Precious metals, coins and gemstones Dealer registration and provenance controls
Creator and subscription platforms Content moderation policy and age verification
Licensed gambling and fantasy sports Operating licence for every market served
Direct marketing Proof of consent-based lists and opt-out handling

Applications in these categories are decided case by case. Approval is not guaranteed, and an approval can be withdrawn if the underlying licence or controls lapse.

08

Use of funds and cards

Restrictions apply at three separate moments: when the account is opened, when a card is issued, and when the card is used. Passing the first two does not authorise the third.

  • Purchase or trade of digital currencies
  • Drug-related purchases, including cannabis, CBD and black-market items
  • Darknet marketplaces and cybercrime services
  • Unlicensed internet pharmacies, or pharmacies operating outside regulated jurisdictions
  • Firearms, ammunition and explosives
  • Hazardous materials and chemicals without regulatory clearance
  • Escort services and similar platforms
  • Unlicensed or illegal auction sites
  • Unregulated lending and payday loan services
  • Data brokerage services
  • Endangered species and wildlife products

Card spending is blocked in sanctioned jurisdictions regardless of where the cardholder resides, and regardless of whether the cardholder is an individual or an entity.

Attempting to route a prohibited purchase through a permitted merchant category is grounds for immediate termination.

09

Data protection

Operator personal data is processed for compliance verification, product operation, fraud prevention, and legal obligations. Azomland does not sell Operator data to third parties.

Agent data, including repository information, KYA score, and transaction history, may be treated as sensitive operational and financial data.

For data subject rights requests, contact [email protected].

10

Contact and reporting

For compliance questions, suspicious activity reports, or data rights requests:

  • General compliance: [email protected]
  • Sanctions or AML concerns: same address, marked "COMPLIANCE URGENT"
  • Data protection requests: same address, marked "DATA REQUEST"

This policy is reviewed at minimum annually and updated following material regulatory changes. Azomland LLC, United States. This document does not constitute legal advice.