Anti-Money Laundering (AML) Policy

1. AML Compliance Officer

AML Compliance Officer: Sivakumar Patchayappan, Chief Compliance Officer

The AML Compliance Officer is responsible for implementing and enforcing this policy, monitoring for suspicious activity, filing required reports, and ensuring ongoing compliance with applicable anti-money laundering laws and regulations.

2. Risk Assessment

Ohey Inc. has assessed its money laundering and terrorist financing risks based on its business model:

• Lower risk factors: Non-discretionary advisory only (no custody, no trade execution); subscription fees processed exclusively through Stripe (a regulated payment processor with its own AML/KYC program); no wire transfers, cash, or cryptocurrency accepted directly; no physical offices open to the public.
• Risk factors monitored: Potential misuse of advisory signals for market manipulation; unusual subscription patterns (rapid upgrades/downgrades, multiple accounts); access from sanctioned jurisdictions.

3. Client Identification and Due Diligence

While Ohey Inc. is not subject to the formal CIP requirements applicable to broker-dealers and banks, the firm collects and verifies the following information at account registration to fulfill its investment adviser obligations:

• Full legal name
• Email address (verified via confirmation link)
• Date of birth
• Employment status
• Investor profile information (risk tolerance, income, net worth, investment experience)

Payment processing and identity verification for billing purposes are handled by Stripe, which maintains its own comprehensive KYC/AML compliance program.

4. Suspicious Activity Monitoring

Ohey Inc. monitors for the following red flags:

• Multiple accounts created from the same IP address or device fingerprint
• Rapid tier changes inconsistent with normal usage patterns
• Access attempts from OFAC-sanctioned countries (blocked at the application level)
• Unusual API usage patterns suggesting automated signal redistribution
• Subscription payments from stolen or fraudulent payment methods (flagged by Stripe)

If suspicious activity is detected, the AML Compliance Officer will review the activity, document the findings, and determine whether a Suspicious Activity Report (SAR) filing with FinCEN is warranted.

5. OFAC Compliance

Ohey Inc. screens new accounts against the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list using automated screening integrated into the account registration process. Accounts matching SDN entries are blocked and reported to the AML Compliance Officer for further review.

Note: OFAC screening is performed at the application level during account creation. Ohey Inc. does not perform ongoing real-time OFAC screening of existing accounts but reviews the SDN list upon material updates published by OFAC.

6. Recordkeeping

In accordance with investment adviser recordkeeping requirements under Rule 204-2, Ohey Inc. maintains:

• Client account registration records (retained for 5 years after account closure)
• Subscription payment records (retained for 5 years)
• Signal access archives documenting advisory content served to each client (retained for 5 years)
• Audit logs of account access and feature usage (retained for 90 days in active storage, archived thereafter)
• Records of any suspicious activity reviews and SAR filings

7. Training

All personnel with access to client data or the authority to open or manage accounts receive AML training upon hire and annually thereafter. Training covers red flag identification, escalation procedures, and regulatory obligations.

8. Independent Review

This AML program will be reviewed annually by independent outside counsel to assess its adequacy and effectiveness, consistent with the firm's Code of Ethics independent review requirement.

9. Contact

For questions about this AML policy:

Ohey Inc.
Pleasanton, CA 94588
Email: [email protected]