Risk, Sanctions & AML Policy
Effective Date: 1.9.2026
SpeedyTurtle Technologies LLC (“SpeedyTurtle,” “Company,” “we,” “us,” or “our”) operates a non-custodial software platform that provides users with tools to interact with public blockchains and third-party protocols. This Policy describes how SpeedyTurtle addresses sanctions compliance, illicit-use prevention, and legal risk without operating as a regulated financial institution.
This Policy is incorporated by reference into the SpeedyTurtle Terms of Service and Privacy Policy.
1. Nature of the Platform
SpeedyTurtle provides technology only. The Services consist of software interfaces and automation tools that allow users to submit transactions to public blockchains.
SpeedyTurtle does not:
custody, hold, or control Digital Assets
operate wallets
access private keys or seed phrases
execute transactions on behalf of users
act as a broker, exchange, money transmitter, or payment processor
Users retain exclusive control over their Wallets and Digital Assets at all times.
2. Turnkey Key Infrastructure
To facilitate secure cryptographic signing, SpeedyTurtle utilizes a third-party key infrastructure provider (currently Turnkey).
Turnkey provides:
hardened, isolated signing environments
cryptographic key management and transaction signing
user-authorized transaction execution
SpeedyTurtle:
does not receive, store, or access private keys
cannot extract, export, or use signing material
cannot initiate transactions without user authorization
Turnkey functions as a technical signing service, not a custodian or financial intermediary.
3. No Financial Institution Status
SpeedyTurtle is not:
a Money Services Business (MSB)
a bank, broker, exchange, or custodian
a financial institution under the Bank Secrecy Act
subject to FATF customer due-diligence or transaction-monitoring obligations
Nothing in this Policy creates a duty to perform Know-Your-Customer (KYC), ongoing AML surveillance, or suspicious activity reporting.
4. Sanctions & Jurisdiction Controls
SpeedyTurtle prohibits use of the Services by:
persons or entities on U.S., EU, UK, or UN sanctions lists
users located in embargoed or restricted jurisdictions
users acting for or on behalf of sanctioned parties
These restrictions are enforced through:
Terms of Service
IP and location-based controls
access restrictions
They are not enforced through custody, wallet surveillance, or transaction control.
5. No Transaction Monitoring or Wallet Surveillance
SpeedyTurtle does not:
monitor blockchain transactions
track user balances
analyze wallet flows
block or reverse transactions
All blockchain activity occurs on public decentralized networks beyond SpeedyTurtle’s control.
Any use of third-party analytics is limited to:
platform security
abuse detection
legal compliance
SpeedyTurtle does not perform AML surveillance of users.
6. Discretionary Risk Controls
SpeedyTurtle reserves the right, but does not assume an obligation, to:
restrict or suspend access
request limited information
terminate accounts
where reasonably necessary to:
comply with Applicable Law
respond to sanctions or court orders
protect against fraud or abuse
These actions are risk-based and discretionary, not financial-institution compliance.
7. Law Enforcement Cooperation
SpeedyTurtle will respond to:
subpoenas
court orders
lawful governmental requests
to the extent required by law.
SpeedyTurtle cannot freeze, reverse, or seize Digital Assets.
8. User Responsibility
Users are solely responsible for:
their Wallets
their transactions
their compliance with laws
their Digital Assets
SpeedyTurtle does not validate, approve, or control any transaction.
9. Updates
This Policy may be updated from time to time. Continued use of the Services constitutes acceptance of the most current version.
10. Contact
Compliance inquiries may be directed to:
SpeedyTurtle Technologies LLC Email: [email protected]
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