Anti-Money Laundering (AML) Policy
Last updated: April 2026
1. Purpose & Policy Statement
AN9 L.L.C. is strictly committed to preventing its digital media and streaming platforms from being used to facilitate money laundering, the financing of terrorism, or other financial crimes. We adhere to all applicable anti-money laundering laws and regulations, including the guidelines set forth by the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN).
2. Know Your Customer (KYC) & Customer Due Diligence (CDD)
While our primary business is direct-to-consumer digital subscriptions, we enforce strict due diligence protocols across all business relationships:
- Corporate Partners & Licensors: Before entering into any media licensing agreements or B2B transactions, AN9 L.L.C. verifies the legal existence of the entity, its beneficial owners, and its operational jurisdiction.
- Consumers: All subscription purchases require verifiable billing information. We rely on our authorized payment gateways to employ Address Verification System (AVS) checks, Card Verification Value (CVV) validation, and 3D Secure (3DS) authentication to confirm user identity and payment legitimacy.
3. Sanctions & OFAC Compliance
AN9 L.L.C. strictly prohibits financial transactions with individuals, entities, or regions subject to economic sanctions. We utilize automated IP filtering and coordinate with our payment processing partners to block transactions originating from comprehensive sanctioned jurisdictions as designated by the U.S. Office of Foreign Assets Control (OFAC).
4. Transaction Monitoring & Fraud Prevention
Our platform utilizes automated risk management systems to monitor for unusual or suspicious transaction patterns indicative of money laundering or fraud, including but not limited to:
- High-velocity transaction attempts (Card Testing).
- Multiple transactions from the same IP address using different credit cards.
- Unusually high subscription volumes from unverified or high-risk geographic locations.
- Significant discrepancies between the user's IP location and the card issuing country.
Any transaction flagged by our system is subject to immediate manual review, suspension, or refund.
5. Suspicious Activity Reporting (SAR)
The designated Compliance Officer (Zi-Xiang Lin) is responsible for identifying and escalating red flags. If illicit activity is suspected, the Compliance Officer will conduct an internal investigation. If the suspicion is substantiated, AN9 L.L.C. will promptly terminate the associated accounts, preserve all digital evidence, and file a Suspicious Activity Report (SAR) with the relevant regulatory and law enforcement authorities.
6. Record Retention
In compliance with federal regulations, AN9 L.L.C. maintains comprehensive records of all financial transactions, user IP logs, and compliance investigations for a minimum period of five (5) years. These records are stored securely and are readily available upon valid request by law enforcement or regulatory agencies.
7. Compliance Officer Contact
Compliance Officer: Zi-Xiang Lin
AN9 L.L.C.
Email: contact@an9llc.com
Mailing Address: 16192 Coastal Highway, Lewes, DE 19958, USA