Compliance & Legal Disclosures

Money Services Business Registration

EBT CONSULTING LLC — the operating entity for Zula LLC's regulated services — is registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN), an agency of the United States Department of the Treasury.

Washington State Money Transmitter License

Zula LLC is licensed as a Money Transmitter in Washington State by the Washington State Department of Financial Institutions (DFI). This license authorizes us to engage in the transmission of money and digital assets within and through the State of Washington.

Federal Regulatory Compliance

We comply with all applicable U.S. federal and state regulations, including but not limited to:

• The Bank Secrecy Act (BSA), 31 U.S.C. § 5311 et seq.
• FinCEN regulations governing money services businesses (31 CFR Part 1022)
• FinCEN guidance on virtual currency (FIN-2013-G001, FIN-2019-G001)
• OFAC sanctions compliance requirements
• Applicable state money transmission laws

Anti-Money Laundering (AML) Program

Zula LLC maintains a comprehensive Anti-Money Laundering compliance program as required by the Bank Secrecy Act. Our AML program includes:

• Written internal policies, procedures, and controls
• Designation of a compliance officer
• Ongoing employee training on AML obligations
• Independent testing and audit of AML controls
• Transaction monitoring for suspicious activity
• Suspicious Activity Report (SAR) filing as required
• Currency Transaction Report (CTR) filing as required
• Recordkeeping in compliance with BSA requirements

Know Your Customer (KYC) Policy

We implement Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures for all customers. Prior to providing any services, Zula LLC requires identity verification including:

• Government-issued photo identification
• Proof of residential address
• Date of birth verification
• Screening against OFAC and other sanctions lists
• Enhanced due diligence for higher-risk customers or transactions

Customers who do not complete our KYC process will not be permitted to use our services. This requirement is non-negotiable and applies to all account types.

Risk Disclosure

Specific risks associated with our services include:

• Price volatility: cryptocurrency values fluctuate significantly and unpredictably
• Technological risk: blockchain networks may experience outages, forks, or security events
• Regulatory risk: laws governing digital assets may change
• Liquidity risk: digital assets may not be readily convertible to fiat currency at a desired price
• Irreversibility: most blockchain transactions cannot be reversed once confirmed
• Loss of access: loss of wallet credentials may result in permanent loss of assets

No Investment Advice

Nothing on this website, in our communications, or through our services constitutes investment advice, financial advice, legal advice, or any other professional advice. Zula LLC is not a registered investment advisor, broker-dealer, or securities firm. Customers are strongly encouraged to consult qualified financial, legal, and tax professionals before using digital asset services.

OFAC Sanctions Compliance

Zula LLC screens all customers and transactions against the Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list and other applicable sanctions lists. We do not provide services to sanctioned individuals, entities, or jurisdictions. We maintain ongoing monitoring and update screening in accordance with OFAC requirements.

Travel Rule Compliance

For qualifying transfers, Zula LLC complies with the FinCEN Travel Rule (31 CFR § 1010.410), which requires that certain identifying information accompany funds transfers of $3,000 or more. We collect and transmit required information for applicable transactions.