AML & Compliance

Oaksvale operates as the tokenization infrastructure for fractional ownership of African real estate. Because the Platform facilitates investment, capital flows, and transfers of value across multiple jurisdictions, we treat compliance not as a procedural obligation but as a foundational principle of how the Platform operates.

We are committed to:

• Conducting business only with verified Users whose identity has been confirmed
• Preventing the use of the Platform for money laundering, terrorism financing, fraud, sanctions evasion, or any other illegal activity
• Cooperating with regulators, financial intelligence units, and law enforcement authorities where lawfully required
• Maintaining accurate records of User identity and transactional activity in accordance with applicable law
• Continuously improving our compliance program as the Platform grows and the regulatory landscape evolves

These commitments apply across every property, every transaction, and every interaction on the Platform.

All Users are required to complete identity verification before participating in regulated activities on the Platform, including primary investments, marketplace transactions, governance participation, and certain wallet operations.

2.1 Information Collected

KYC verification requires Users to provide:

• Full legal name
• Date of birth
• Residential address
• Phone number
• A valid international passport, including passport identification number
• A digital signature acknowledging acceptance of relevant agreements

Additional information or documentation may be requested where required to satisfy enhanced due diligence obligations.

2.2 Verification Process

Identity verification is conducted by Oaksvale. The verification process includes:

• Identity document authentication
• Risk-based assessment of jurisdictional exposure

Users may be required to undergo enhanced due diligence where their profile, jurisdiction, or transactional behavior indicates elevated risk.

2.3 Restrictions for Non-Verified Users

Users who have not completed KYC verification may browse the Platform but may not invest in Property DAOs, vote in governance, list or purchase units on the marketplace, or perform other restricted actions. A persistent verification prompt is shown to non-verified Users.

Oaksvale maintains a risk-based AML program designed to detect, prevent, and report potential money laundering and terrorism financing activity.

3.1 Risk Assessment

We assess AML risk across multiple dimensions, including:

• User risk — based on identity, jurisdiction, source of funds, and behavioral patterns
• Transactional risk — based on the size, frequency, and nature of transactions
• Property risk — based on the location, type, and structure of underlying assets
• Jurisdictional risk — based on the regulatory and AML environment in relevant jurisdictions

Our compliance program calibrates the level of due diligence and monitoring applied to each User and transaction based on these risk dimensions.

3.2 Transaction Monitoring

All transactions on the Platform are monitored for indicators of suspicious activity, including but not limited to:

• Transactions that appear inconsistent with a User's established profile
• Patterns suggesting structuring or layering
• Unusual frequency, size, or routing of transactions
• Connections to wallets or counterparties associated with sanctions, fraud, or illicit activity
• Behavioral anomalies that may indicate compromised accounts or unauthorized use

Where suspicious activity is identified, Oaksvale may delay, restrict, or reject transactions, request additional information, or suspend accounts pending review.

3.3 Suspicious Activity Reporting

Where Oaksvale identifies activity that meets the threshold for reporting under applicable AML law, we will file a Suspicious Activity Report (or equivalent report) with the relevant financial intelligence unit or regulatory authority. We do this in accordance with applicable law and without notifying the affected User, as required by AML reporting frameworks.

4.4 Source of Funds and Source of Wealth

For larger investments, Users may be required to provide evidence of source of funds and, where applicable, source of wealth. This is a standard requirement under enhanced due diligence frameworks and is intended to ensure that capital invested through the Platform comes from legitimate sources.

Oaksvale maintains records of User identity, KYC documentation, transactional activity, and compliance decisions in accordance with applicable AML record-keeping requirements. Records are typically retained for a minimum of five (5) to seven (7) years from the end of the User relationship, or longer where required by specific jurisdictional rules.

These records are stored securely, are accessible only to authorized personnel, and may be disclosed to regulatory authorities or law enforcement where lawfully required.

Oaksvale's compliance program is overseen by designated compliance personnel responsible for:

• Day-to-day administration of the KYC and AML programs
• Reviewing and escalating suspicious activity
• Engaging with regulators and external auditors
• Conducting periodic reviews of compliance policies and procedures
• Training Oaksvale personnel on compliance obligations

Where required by applicable law, Oaksvale will appoint a designated Money Laundering Reporting Officer (MLRO) or equivalent function. Compliance policies are reviewed periodically and updated to reflect changes in law, regulation, or platform operations.

Oaksvale facilitates investment in tokenized real estate assets across multiple African jurisdictions, with Users based in numerous countries worldwide. Because legal and regulatory environments vary substantially across these jurisdictions, the following principles apply:

6.1 Property Jurisdiction

Each Property DAO is associated with a specific jurisdiction in which the underlying real estate is located and the relevant Special Purpose Vehicle (SPV) is registered. The legal and regulatory framework applicable to that property is determined by that jurisdiction.

6.2 User Jurisdiction

Users access the Platform from their countries of residence. Local laws in each User's jurisdiction may impose additional requirements, restrictions, or tax obligations on participation in tokenized real estate investment. Users are responsible for understanding and complying with the laws applicable to them in their own jurisdiction.

6.3 Restricted Jurisdictions

Oaksvale does not offer the Platform to Users in jurisdictions where its services would be unlawful, where it is not authorized to operate, or where doing so would expose Oaksvale or its Users to unacceptable legal or regulatory risk. The list of restricted jurisdictions is reviewed periodically and may be updated based on regulatory developments.

6.4 No Solicitation Where Unauthorized

Oaksvale does not solicit Users, market its services, or accept investment from any jurisdiction where such activity would constitute an unauthorized offering or solicitation of regulated investment products. The availability of the Platform in any specific jurisdiction does not imply that Oaksvale is licensed or authorized in that jurisdiction.

6.5 No Investment Advice

The Platform provides infrastructure for tokenized real estate investment, not investment advice. Oaksvale does not assess the suitability of any specific investment for any specific User, does not make investment recommendations, and does not act as a financial adviser. Users are solely responsible for their investment decisions and are encouraged to seek independent professional advice.

Oaksvale cooperates with regulators, financial intelligence units, law enforcement, and other competent authorities in their lawful exercise of their duties, including:

• Responding to lawful requests for information
• Disclosing User information where required by court order, regulatory directive, or applicable law
• Participating in regulatory examinations and reviews
• Reporting suspicious activity in accordance with applicable AML law

We do not voluntarily disclose User information to third parties beyond what is required by law, contract, or our published privacy and compliance commitments.

Users have the following obligations under this Policy:

• Provide accurate information. All KYC and account information provided to Oaksvale must be truthful, accurate, and complete.
• Update information promptly. Users must notify Oaksvale of material changes to their identity, address, residency, or other KYC information.
• Comply with applicable law. Users are responsible for complying with the laws applicable to them in their jurisdiction of residence and any other jurisdiction relevant to their activity.
• Cooperate with verification. Users must respond to reasonable requests for additional information, documentation, or clarification in connection with KYC, transaction monitoring, or compliance reviews.
• Use the Platform lawfully. Users may not use the Platform to launder funds, finance terrorism, evade sanctions, commit fraud, or engage in any other illegal activity.

Failure to meet these obligations may result in suspension or termination of the User's account, restriction of Platform access, or reporting to relevant authorities.

Where a User fails to meet KYC or AML obligations, or where suspicious activity is identified, Oaksvale may take any of the following actions:

• Request additional information or documentation
• Restrict access to specific Platform features
• Delay, reject, or reverse transactions where lawfully possible
• Suspend or terminate the User's account
• Report the matter to relevant authorities

These actions are taken in accordance with applicable law and our internal compliance policies, and are not subject to negotiation or waiver.

Oaksvale may update this AML & Compliance Policy from time to time to reflect changes in law, regulation, Platform operations, or compliance practices. The "Last Updated" date at the top of this Policy reflects the most recent change. Users are encouraged to review this Policy periodically.

For questions, concerns, or notices related to this AML & Compliance Policy:

Email: contact@oaksvale.com