Legal & Compliance

A. Company Information

B. Regulatory Compliance

FinCEN Registration and BSA Compliance

DIRE MONEY TRANSMITTER LLC is registered with the Financial Crimes Enforcement Network (FinCEN) as a Money Services Business under 31 CFR Part 1022. As an MSB engaged in money transmission involving digital assets, we maintain an Anti-Money Laundering (AML) program that satisfies the requirements of the Bank Secrecy Act (BSA), 31 U.S.C. 5311 et seq. Our AML program includes written policies and procedures, a designated compliance officer, ongoing employee training, independent testing, and a risk-based customer due diligence process.

USA PATRIOT Act Compliance

BlueMesa Exchange complies with applicable provisions of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act), Pub. L. 107-56. This includes maintaining a Customer Identification Program (CIP) that verifies the identity of all account holders before providing services. We screen all customers against OFAC's Specially Designated Nationals and Blocked Persons list and other applicable sanctions lists.

State Money Transmission Licensing

State-level money transmission licensing requirements vary significantly by jurisdiction. DIRE MONEY TRANSMITTER LLC pursues state licensing in jurisdictions where it is required to operate. Services through BlueMesa Exchange may not be available in all states. Customers are informed of service availability in their state during the registration process.

Services may not be available in all states. Availability is subject to change as licensing status is updated.

C. AML/KYC Policy Summary

Identity Verification Requirements

All account holders must complete identity verification before accessing trading or wallet services. Retail account holders must provide a valid government-issued photo ID, proof of current address, and complete a live identity confirmation step. Business account holders must additionally provide entity formation documents, EIN, and beneficial ownership disclosure for individuals with 25% or more ownership interest, as required by FinCEN's Customer Due Diligence (CDD) Rule, 31 CFR 1010.230.

Transaction Monitoring

All transactions on the BlueMesa Exchange platform are subject to automated and manual monitoring for suspicious activity. Our monitoring program is designed to detect patterns associated with money laundering, terrorist financing, and other financial crimes. Monitoring thresholds and parameters are reviewed and updated regularly by our compliance team.

Suspicious Activity Reporting

Where our monitoring identifies activity that meets the criteria for a Suspicious Activity Report (SAR) under 31 CFR 1022.320, we are required by federal law to file a SAR with FinCEN. We are prohibited by law from disclosing to any person that a SAR has been filed or is under consideration. We are also required to file Currency Transaction Reports (CTRs) for transactions exceeding applicable thresholds under 31 CFR 1010.311.

No Anonymous Transactions

No anonymous transactions are permitted on BlueMesa Exchange. Every transaction is associated with a verified account holder. Accounts that fail to complete or maintain compliance with identity verification requirements will be suspended or closed.

D. Cryptocurrency Risk Disclosure

E. Consumer Protections

Error Resolution Procedures

If you believe an error occurred in your account, notify us in writing within sixty (60) days of the date the error appears on your account statement or transaction record. Your notice must include your account information, the date and amount of the alleged error, and a description of the error. We will acknowledge receipt of your dispute and complete our investigation within the timeframes required by applicable law. If an error is confirmed, we will correct it promptly. If we determine no error occurred, we will provide you with a written explanation of our findings. You may request copies of documents we relied upon in our investigation.

Complaint Submission Process

Formal complaints may be submitted in writing to DIRE MONEY TRANSMITTER LLC at 2026 S Brentwood Blvd Suite 204, St. Louis, MO 63144, or by email to support@bluemesa.co.com. All complaints are logged and assigned a reference number. We will investigate and respond in writing. If you are not satisfied with our response, you may contact your state's financial regulatory authority or file a complaint with the Consumer Financial Protection Bureau (CFPB) at consumerfinance.gov.

Cancellation Rights

Certain prepaid or scheduled transactions may be cancelled before execution. Cancellation rights, where applicable, will be disclosed at the time of the transaction. Once a transaction has been executed and confirmed on a blockchain network, it cannot be reversed. We are not able to reverse completed on-chain transactions.

F. Data Protection

Privacy Practices

DIRE MONEY TRANSMITTER LLC collects and processes personal information as described in our Privacy Policy. Personal information is collected for account verification, transaction processing, regulatory compliance, and platform operation. We do not sell personal information to third parties for marketing purposes. Data is retained for the periods required by the Bank Secrecy Act and other applicable law.

California Consumer Privacy Act (CCPA)

California residents have rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), including the right to know what personal information is collected, the right to delete personal information (subject to legal retention requirements), the right to correct inaccurate information, and the right to opt out of the sale or sharing of personal information. We do not sell personal information. To exercise your California privacy rights, contact us at support@bluemesa.co.com. Note that information subject to BSA retention requirements may not be eligible for deletion.