KYC / AML / PAYMENT INTEGRITY POLICY - FLOCKTOGETHER.XYZ

This KYC / AML / Payment Integrity Policy ("Policy") governs how Flock Together Global LLC ("Flock," "we," "us," "our") verifies identity, prevents fraud, combats money laundering, and ensures payment legitimacy onhttps://flocktogether.xyz (the "Platform").

This Policy is incorporated into and forms part of:

• Terms of Service
• Creator Agreement / Monetization Policy
• Privacy Policy
• Acceptable Use Policy
• Refunds & Chargebacks Policy

By using our monetization features, payouts, or digital earnings tools, you agree to comply with this Policy.

Following the completion of the Beta phase, all eligible creators are able to earn from their first day on the Platform, subject to successful identity verification, KYC/AML checks, and this Policy.

1. PURPOSE

This Policy protects:

• Creators
• Users
• Advertisers
• Payment processors
• The platform itself

Our goals are to:

• Prevent fraudulent earnings
• Stop monetization laundering
• Verify payout identities
• Comply with international anti-money laundering laws
• Reduce regulatory exposure

We follow FATF, FinCEN, KYC, and AML best practices where applicable.

2. KYC REQUIREMENTS

2.1 Identity Verification

Creators must verify their identity before withdrawing funds.

Verification may include:

• Government-issued ID
• Passport or National ID
• Banking statement
• Phone verification
• Email verification
• Selfie or video match

Flock reserves the right to request:

• Additional documentation
• Proof of residency
• Tax documents
• Beneficial ownership information

Failure to comply may result in withholding, delaying, or forfeiture of earnings, and/or suspension of monetization.

3. MINIMUM AGE

To monetize:

• Creators must be 18+ (or the age of majority in their jurisdiction).

Minors may upload content, but monetization requires:

• A legally documented parent/guardian pathway
• A verified adult-controlled payout account

We do not pay directly to underage individuals.

4. ACCOUNT MATCHING

All payout accounts must match:

• Legal name
• Government identity
• Banking profile

We may deny payout if:

• Names do not match
• Accounts appear to be shared or rented
• Proxy ownership is detected

Creators may not:

• Sell earnings pipelines
• Lease payout channels
• Operate monetization for banned users

5. PAYMENT PROCESSOR VERIFICATION

We partner with:

• Payoneer
• PayPal
• Stripe
• Other approved regional financial services

Creators agree to comply with each provider's terms.

If a processor requests KYC:

• Flock is not liable for delays
• Verification is between Creator and provider
• Refusal or failure may lead to payout suspension or account review

6. PROHIBITED COUNTRIES & SANCTIONS

We comply with:

• US OFAC sanctions
• EU/UK sanctions lists
• FATF blacklists
• Canadian and Australian AML controls

Users from restricted jurisdictions may be:

• Denied monetization
• Have payout locked
• Have accounts suspended

We may block:

• Certain IP ranges
• Suspicious networks
• VPN-based masking where it indicates risk

7. MULTIPLE ACCOUNTS

Flock allows Creators to maintain more than one content account, provided all accounts:

• Are linked to the same verified identity
• Comply with this Policy and all Platform rules

Creators may not:

• Operate multiple earning accounts under different identities to hide ownership
• Split or route earnings between accounts to obscure who is getting paid
• Create "farm" networks for artificial engagement or monetization abuse

We reserve the right to merge, restrict, close, or ban accounts used to evade detection, enforcement, or KYC/AML controls.

8. FRAUD & ABUSE INDICATORS

We monitor, directly or via partners:

• Rapid earnings spikes
• Unusual traffic origins
• VPN or proxy-heavy activity
• Click fraud
• Purchased views or bots
• Coordinated artificial engagement
• Suspicious referral or affiliate patterns

If flagged:

• Monetization may be paused
• Payouts may be frozen pending review
• Revenue may be voided where fraud is confirmed

9. MONETIZATION LAUNDERING

Prohibited:

• Using Flock to move money between individuals
• Using ads as a disguised payment mechanism
• Self-purchased traffic
• "Content washing" through private or closed networks

We may:

• Suspend or permanently ban accounts
• Notify financial partners and payment processors
• Notify law enforcement or regulators where required

10. PAYMENT REVERSALS & CHARGEBACKS

If a user or creator files repeated or suspicious chargebacks or payment disputes:

• Accounts may be frozen
• Revenue may be voided
• Monetization may be disabled
• A permanent ban may be enforced in severe or persistent cases

We treat chargebacks as a high-risk fraud signal, especially when patterns indicate abuse.

11. THIRD-PARTY OWNERSHIP

Creators may not:

• Operate accounts for banned individuals
• Cash out earnings on behalf of third parties as a "pass-through"
• Use nominee or proxy accounts
• Sell or rent payout access

This behavior is grounds for immediate termination and forfeiture of earnings.

12. CRYPTOCURRENCY

At this time:

• Flock does not accept cryptocurrency payouts
• Flock does not facilitate wallet-based earnings

Crypto-related features may be introduced in future phases subject to strict KYC/AML and regulatory compliance.

13. AI-ASSISTED FRAUD

We monitor:

• AI engagement bots
• Auto-comment spam
• Automated "watch farms"
• Mass AI-generated uploads whose primary purpose is to harvest ad revenue

Flock may:

• Deny monetization
• Freeze earnings
• Close accounts
• Ban device identifiers

Earnings derived from fraud are permanently forfeited.

14. IDENTITY MISMATCHES

If name or identity mismatches occur:

• We may request additional documents
• We may refuse payout
• Monetization may be temporarily or permanently disabled

Examples triggering review:

• Celebrity or fake names that do not match legal ID
• Business names that do not match the registered creator or owner
• Rapid or unexplained change of payout beneficiary
• Offshore payments for creators whose activity appears local only

15. REQUESTS FOR INFORMATION

We may ask for:

• Legal name
• Address
• Birth date
• Banking details
• Tax records
• Proof of residency
• Phone verification
• "Source of funds" or "source of traffic" explanation

Non-cooperation may suspend monetization and payouts until the issue is resolved.

16. FUND FREEZES

We may freeze balances:

• During disputes
• When fraud is detected
• Pending copyright challenges
• For AML risk assessments
• If sanctions are suspected

Balances may be withheld for up to 180 days, or longer if required by law, the payment provider, or law enforcement.

17. TERMINATION CONSEQUENCES

If this Policy is violated:

• Earnings may be voided
• Monetization may be disabled
• Account(s) may be permanently banned
• Relevant authorities or partners may be notified

Creators whose earnings arise from fraudulent, abusive, or illegal activity forfeit all balances related to that activity.

18. AUDIT RIGHTS

Flock reserves the right to:

• Audit accounts
• Review monetization events
• Inspect traffic sources
• Verify payout identity and ownership

Creators must cooperate in good faith or risk suspension or removal.

19. PRIVACY

Data collected under KYC/AML is:

• Stored securely
• Used only for verification, compliance, and fraud prevention
• Shared with payment processors or partners when required for compliance

We do not sell identity or KYC data.

20. REGULATORY COOPERATION

We may cooperate with:

• Tax authorities
• Police and cybercrime units
• Regulatory agencies
• Financial intelligence units

We may disclose:

• Account IDs and basic profile data
• IP logs and device identifiers
• Traffic and monetization analysis
• Payout history
• Confirmed fraud records

21. POLICY UPDATES

We may update this Policy at any time.

Continued use of monetization features and payout tools constitutes acceptance of the updated Policy.

22. CONTACT

For identity, verification, or payout-related questions:

• Support: support@flocktogether.xyz

Legal Entity:

Flock Together Global LLC

30 N Gould St #53789

Sheridan, WY 82801

USA