1. Purpose
Mapstone Labs LLC, doing business as Mapstone ("Mapstone" or the "Company"), is committed to conducting its business in compliance with applicable U.S. laws relating to money laundering, terrorist financing, economic sanctions, fraud, and other illicit financial activity. This policy establishes Mapstone's risk-based procedures for identifying, preventing, and responding to potentially unlawful use of the Mapstone platform.
2. Business Model
Mapstone operates an Ethereum-based platform through which users can mint and trade ERC-721 NFTs associated with real-world street addresses and postal codes. Users interact with Mapstone through their own self-custodied digital-asset wallets. Mapstone does not provide hosted wallets, maintain customer account balances, accept customer deposits, or transmit fiat or cryptocurrency on behalf of users. Mapstone receives company-owned revenue from platform activity and maintains its corporate digital assets through company-controlled wallets and third-party financial or custody providers, as applicable.
3. Risk-Based Compliance
Mapstone takes reasonable, risk-based measures designed to prevent the platform from being knowingly used for money laundering, terrorist financing, sanctions evasion, fraud, or other unlawful activity. Mapstone may review transactions, wallet activity, account information, or other relevant information when circumstances warrant additional review.
4. Sanctions Compliance
Mapstone will not knowingly conduct business with persons or entities subject to applicable U.S. economic sanctions or permit the platform to be knowingly used to evade applicable sanctions. Where appropriate, Mapstone may restrict access to its services, decline a transaction or distribution, or require additional information when necessary to address sanctions or other compliance concerns.
5. Address Quest and Identity Verification
Mapstone may require identity verification, sanctions screening, tax documentation, or other information from Address Quest participants before distributing prizes or other rewards when required by the applicable competition rules, law, or Mapstone's compliance procedures. Mapstone may withhold or decline a distribution where a participant fails required verification or where completing the distribution would violate applicable law.
6. Prohibited Activity
Mapstone prohibits use of its platform for unlawful activity, including money laundering, terrorist financing, sanctions evasion, fraud, theft, trafficking in illicit proceeds, or attempts to conceal the source or ownership of unlawfully obtained assets. Mapstone may restrict or terminate access to the platform where it reasonably determines that activity violates applicable law, Mapstone's Terms and Conditions, or this policy.
7. Review of Potentially Suspicious Activity
If Mapstone identifies activity presenting a material compliance concern, the Company may review available account, transaction, wallet, and blockchain information and take appropriate action based on the circumstances. Such action may include requesting additional information, restricting access where technically feasible, declining a transaction or distribution, terminating an account, or referring information to law enforcement or other authorities where required or appropriate.
8. Records and Cooperation
Mapstone maintains business and transaction records appropriate to its operations and will provide information to law enforcement, regulators, courts, or financial institutions when required by applicable law or valid legal process.
9. Responsibility and Review
Mapstone management is responsible for administering this policy and periodically reviewing it in light of changes to the Company's operations, applicable law, and identified compliance risks. This policy may be amended from time to time as Mapstone's business and compliance requirements evolve.