§Policy
Compliance
GPU compute and AI models sit under sanctions and export-control rules, and money moving between countries sits under anti-money-laundering law. These are the rules DaoWorks applies to every client, provider and deal.
Updated
What we screen against
- Sanctions
- UN Security Council · US (OFAC) · European Union · United Kingdom · Hong Kong
- Export controls
- US Export Administration Regulations, including the Entity List
- Records kept
- At least seven years
01
Know who we deal with
We identify and verify every client and provider from company registry documents, and identify the people who own or control them — beneficial owners with more than 25% and anyone else with control. Individuals are verified from their passports.
02
Sanctions screening
Clients, providers and their beneficial owners are screened against the sanctions lists of the United Nations, the United States (OFAC), the European Union, the United Kingdom and Hong Kong, when we engage and again before each introduction. We don't deal with anyone in a comprehensively sanctioned country or region.
03
Export controls
Advanced GPUs and related technology are controlled under the US Export Administration Regulations (EAR). For each compute deal we check where the hardware is, who will use it and for what, and screen the parties against the US Entity List and other restricted-party lists. We don't introduce deals involving export-controlled items going to restricted destinations, end users or end uses.
04
How money moves
DaoWorks doesn't hold client funds and doesn't make or receive payments on behalf of third parties. Buyers pay providers directly. The only money DaoWorks receives is its own commission, invoiced to the buyer and paid from the buyer's own account.
05
Records
We keep identification records, screening results, agreements and transaction records for at least seven years.
06
Suspicious activity
If we know or suspect that a deal involves the proceeds of crime or terrorist financing, we report it to Hong Kong's Joint Financial Intelligence Unit, as Hong Kong law requires, and we don't proceed.
Sources UN Security Council Consolidated List · OFAC Sanctions List Search · EU Sanctions Map · UK Sanctions List · Hong Kong: UN Security Council sanctions (CEDB) · Export Administration Regulations, 15 CFR 730–774 · BIS Entity List · JFIU: suspicious transaction reports
07Boundaries
What we won't do.
No resale
We don't take title to compute or tokens, so there's no resale markup inside the provider's price.
No client funds
You pay the provider directly. We never hold client money or pay providers on anyone's behalf.
No crypto services
“Tokens” here means AI model usage. We don't offer crypto or other digital-asset services.
No restricted parties
No sanctioned countries, regions or listed parties, and no deal that fails an export-control check.
08Requests
Documents and questions.
Banks, payment providers and counterparties can request our company documents or ask about these checks by email. Please put “Compliance” in the subject.