Legal & Compliance

Company Information

Regulatory Compliance

FinCEN Registration and BSA Compliance

DIRE MONEY TRANSMITTER LLC is registered with the Financial Crimes Enforcement Network (FinCEN) as a Money Services Business pursuant to 31 C.F.R. § 1022.380. As a registered MSB engaged in money transmission and virtual currency exchange, the Company is subject to the Bank Secrecy Act (BSA), 31 U.S.C. § 5311 et seq., and implementing regulations at 31 C.F.R. Chapter X.

The Company maintains a written AML compliance program that satisfies the requirements of 31 C.F.R. § 1022.210, including designation of a compliance officer, internal controls, employee training, and independent testing.

USA PATRIOT Act Compliance

Consistent with Section 352 of the USA PATRIOT Act (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001), DIRE MONEY TRANSMITTER LLC maintains a comprehensive anti-money laundering program. Our Customer Identification Program (CIP) complies with the requirements applicable to money services businesses under 31 C.F.R. § 1022.210(d)(1)(iv).

State Money Transmission Licensing

The offer and sale of money transmission services is regulated at the state level in the United States. DIRE MONEY TRANSMITTER LLC holds or is in the process of obtaining state money transmission licenses in states where such licensing is required. Ashford services are available only in states where the Company is appropriately licensed or where an applicable exemption exists.

Services may not be available in all states. Availability is confirmed during the account registration process.

AML/KYC Policy Summary

Identity Verification Requirements

All Ashford accounts require identity verification before trading or fund movement is enabled. Users must provide a government-issued photo identification document, full legal name, date of birth, residential address, and taxpayer identification number or equivalent where required. This process satisfies the Customer Identification Program requirements applicable to money services businesses.

Transaction Monitoring Program

DIRE MONEY TRANSMITTER LLC operates a transaction monitoring program designed to detect transactions that may indicate money laundering, terrorist financing, or other financial crimes. Monitoring is conducted on an ongoing basis across all account activity. Unusual patterns, structuring, or transactions inconsistent with a customer's stated profile may trigger enhanced review.

Suspicious Activity Reporting

The Company files Suspicious Activity Reports (SARs) with FinCEN in accordance with 31 C.F.R. § 1022.320 when transactions meet applicable reporting thresholds or exhibit indicators of suspicious activity. Federal law prohibits disclosure to customers that a SAR has been filed.

No Account Without Verification

Ashford does not offer accounts or services to individuals who have not completed identity verification. This policy applies without exception. Partial or incomplete verification results in account restrictions until verification is completed.

Cryptocurrency Risk Disclosure

Consumer Protections

Error Resolution Procedures

If you believe an unauthorized or erroneous transaction has occurred on your Ashford account, you should contact us promptly at support@ashford.co.com. Please include your account identifier, the date and amount of the disputed transaction, and a description of the error. We will review reported issues and respond within a commercially reasonable timeframe consistent with applicable regulatory requirements.

Complaint Submission

Complaints regarding Ashford services may be submitted to support@ashford.co.com. We acknowledge receipt of all complaints and aim to provide a substantive response within 10 business days. Complaints that cannot be resolved to your satisfaction may be escalated to applicable state regulators or the Consumer Financial Protection Bureau (CFPB).

Cancellation Rights

Where applicable under state money transmission laws, users may have rights to cancel pending transactions. Cancellation rights vary by state and transaction type. Blockchain-confirmed transactions are generally irreversible. Contact support@ashford.co.com immediately if you wish to attempt cancellation of a pending transaction.

Data Protection

Privacy Practices Summary

DIRE MONEY TRANSMITTER LLC collects and processes personal information as described in our Privacy Policy. Personal information collected during identity verification is retained for a minimum of five years following account closure, as required by the BSA. We do not sell personal information to third parties. Information is shared with regulatory authorities as required by law.

California Residents — CCPA

California residents have rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). These rights include the right to know what personal information is collected, the right to request deletion of personal information (subject to legal retention obligations), and the right to opt out of the sale of personal information. We do not sell personal information. To exercise CCPA rights, contact support@ashford.co.com.