Compliance & Licensing

Regulatory Compliance

DIRE MONEY TRANSMITTER LLC is registered with the Financial Crimes Enforcement Network (FinCEN) as a Money Services Business. This registration is maintained pursuant to 31 C.F.R. Part 1022 and the Bank Secrecy Act (31 U.S.C. 5311 et seq.). As a registered MSB engaged in virtual currency exchange, the Company is subject to BSA requirements including the maintenance of an anti-money laundering program, the filing of Currency Transaction Reports (CTRs) where applicable, the filing of Suspicious Activity Reports (SARs) where required, and recordkeeping obligations as specified in applicable FinCEN regulations.

The Company also operates in compliance with requirements imposed by the USA PATRIOT Act (Public Law 107-56), specifically Title III (International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001), which imposes customer identification program requirements on financial institutions including Money Services Businesses.

State-level money transmission licensing is obtained and maintained where required by applicable state law. Services may not be available in all states. The availability of Aurelionis services in specific jurisdictions is subject to applicable state licensing requirements. Users are responsible for confirming that use of the Platform is permitted in their jurisdiction.

AML and KYC Program

DIRE MONEY TRANSMITTER LLC maintains a written Anti-Money Laundering program as required under 31 C.F.R. 1022.210. The AML program includes a system of internal controls reasonably designed to assure ongoing compliance with the Bank Secrecy Act and FinCEN regulations, designation of a compliance officer responsible for day-to-day compliance, ongoing training for applicable personnel, and independent testing to monitor and maintain an adequate program.

All accounts on the Aurelionis platform require identity verification under the Company's Customer Identification Program (CIP) prior to account access. The CIP is designed to comply with the requirements of 31 C.F.R. 1022.210 and FinCEN's guidance on virtual currency businesses. Information collected during identity verification includes at minimum the customer's full legal name, date of birth, address, and identification number as required by applicable regulations.

For business accounts, the Company applies enhanced due diligence procedures consistent with FinCEN's Customer Due Diligence rule (31 C.F.R. 1010.230), including collection of beneficial ownership information for legal entity customers meeting applicable thresholds. Ongoing monitoring of account activity is conducted as part of the AML program. Accounts exhibiting patterns consistent with suspicious activity are subject to review, and reports are filed as required by law.

Risk Disclosure

Cryptocurrency and digital assets involve substantial risk of loss. The value of digital assets is highly volatile and can decrease significantly, rapidly, and without warning. Users may receive back less than the amount they invested. The following disclosures apply to all use of the Aurelionis platform.

Not FDIC Insured. Digital assets held through Aurelionis are not bank deposits and are not insured by the Federal Deposit Insurance Corporation (FDIC). No government agency insures or guarantees digital assets held on the platform.

Not Bank Guaranteed. Digital assets are not guaranteed by any bank or banking institution. DIRE MONEY TRANSMITTER LLC is not a bank and does not offer any bank-equivalent protections on digital assets.

Past Performance. Past price performance of any digital asset is not indicative of future results. Historical data regarding digital asset prices should not be relied upon as a predictor of future value.

Not Investment Advice. Nothing on the Aurelionis platform, website, or in any communication from DIRE MONEY TRANSMITTER LLC constitutes investment advice, financial advice, tax advice, or legal advice. Users make their own decisions regarding digital asset transactions and bear full responsibility for those decisions and their consequences.

Consumer Protections and Error Resolution

Users who believe an error has occurred in connection with a transaction on the Aurelionis platform should contact DIRE MONEY TRANSMITTER LLC promptly at support@aurelionis.org. Error resolution procedures are maintained in accordance with applicable federal and state consumer protection requirements applicable to money services businesses.

Users who wish to file a complaint regarding Aurelionis services may contact the Company directly at support@aurelionis.org. Complaints that cannot be resolved directly with the Company may be directed to applicable state regulatory agencies in the user's jurisdiction, or to FinCEN where the complaint relates to federal regulatory obligations. Contact information for state money transmission regulators is available through the Conference of State Bank Supervisors (CSBS) at csbs.org.

Nothing in the Company's complaint procedures limits a user's right to pursue remedies available under applicable federal or state law.

Data Protection and CCPA Compliance

DIRE MONEY TRANSMITTER LLC collects and processes personal information in connection with the operation of the Aurelionis platform. Data collection and processing practices are described in detail in the Privacy Policy available at aurelionis.org/privacy.html. The Company complies with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (CCPA/CPRA) and other applicable state privacy laws.

California residents and residents of other states with enacted comprehensive privacy legislation have specific rights with respect to their personal information. These rights include the right to know, the right to delete, the right to correct, and the right to opt out of certain processing activities. To exercise applicable rights, contact support@aurelionis.org.