AML & Sanctions Policy
Last Updated: August 4, 2026
This policy describes Candle’s approach to anti-money-laundering, counter-terrorist-financing, and economic sanctions. It forms part of the Terms of Service.
1. Statement
Section titled “1. Statement”7 Candlesticks, Inc. is committed to complying with applicable economic sanctions and financial crime laws, and to preventing the Candle Services being used to launder money, finance terrorism, or evade sanctions.
Candle does not tolerate use of its services for financial crime. Candle may restrict or suspend access based on applicable law, its contractual rights, and the information reasonably available to it, and will make reports to authorities when legally required.
2. What Candle is
Section titled “2. What Candle is”This policy describes contractual restrictions and risk controls; it is not a representation that Candle maintains the compliance programme required of a regulated financial institution. Candle must reassess federal and state licensing and compliance obligations whenever product functionality or applicable law changes.
3. Sanctions
Section titled “3. Sanctions”Lists screened
Section titled “Lists screened”Candle’s sanctions controls may use the following authoritative lists. This list does not state that every user, wallet, or transaction is currently screened against every source:
- OFAC Specially Designated Nationals and Blocked Persons (SDN) list and Consolidated Sanctions List
- UK Sanctions List (OFSI)
- EU Consolidated Financial Sanctions List
- UN Security Council Consolidated List
Who is prohibited
Section titled “Who is prohibited”You may not use the Candle Services if you are a Sanctioned Person — designated on any of those lists, owned or controlled 50% or more in aggregate by one or more designated persons, or acting on behalf of such a person.
You may not use the Candle Platform if you are located in, resident in, or incorporated in a Prohibited Jurisdiction. The current list is at Prohibited & Restricted Jurisdictions.
Controls applied
Section titled “Controls applied”Candle may apply risk-based controls including:
- Geolocation screening of IP addresses, and blocking of access from prohibited jurisdictions
- Screening of wallet addresses against sanctions lists and known illicit-activity designations
- Screening of account identifiers — names and linked social accounts — against sanctions lists
- Blocking or freezing platform access where a match or credible indication is identified
- Prohibition of VPN, proxy, and other circumvention used to disguise location
4. Prohibited use
Section titled “4. Prohibited use”You must not use the Candle Services to:
- launder the proceeds of crime, or conceal the origin of funds;
- finance terrorism or proliferation;
- evade sanctions, or facilitate evasion by another person;
- transact with a Sanctioned Person or on their behalf;
- transact with funds you know or suspect derive from criminal conduct;
- structure transactions to avoid screening or reporting;
- obscure the source or destination of funds, including through mixers or tumblers, where the purpose is to defeat screening;
- commit or facilitate fraud, market manipulation, or theft.
5. Identity verification
Section titled “5. Identity verification”Candle does not currently require identity verification for general use of a non-custodial interface.
Candle may require verification — including identity documents, proof of address, source of funds, or wallet ownership attestation — where it identifies elevated risk, where it is required by law, or as a condition of continued access. Refusal to provide it may result in suspension.
6. Monitoring and reporting
Section titled “6. Monitoring and reporting”Candle may review platform activity for indicators of financial crime, including manipulation and interaction with addresses associated with illicit activity. This statement does not promise continuous transaction monitoring.
Where Candle identifies conduct requiring it, Candle will:
- suspend or terminate access and refuse to process transactions;
- preserve relevant records;
- file reports with the relevant authorities where required by law; and
- respond to lawful requests as described in the Law Enforcement Guidelines.
Where the law prohibits disclosure of a report, Candle will not notify the person concerned.
7. What Candle cannot do
Section titled “7. What Candle cannot do”8. Records
Section titled “8. Records”Candle retains relevant records for periods proportionate to security, dispute, and compliance needs and for any longer period applicable law requires. The five-year recordkeeping periods imposed on certain regulated financial institutions do not apply merely because this policy exists. See the Privacy Policy.
9. Governance
Section titled “9. Governance”Responsibility for this policy sits with Candle’s management. It should be reviewed at least annually and after a material change to Candle’s services or applicable law. Personnel with compliance responsibilities should receive training appropriate to their role.
10. Reporting a concern
Section titled “10. Reporting a concern”If you believe the Candle Services are being used for financial crime, email legal@candle.tv with COMPLIANCE at the start of the subject line. Include the wallet address, account, token, or transaction concerned, and what you observed.
Questions: legal@candle.tv