Last Updated: March 26, 2025
RBHGROUP (incorporated in the United States) is registered Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN) and operates Delulu, an on-chain trading platform. As an MSB, RBHGROUP complies with the Bank Secrecy Act (BSA), 31 U.S.C. § 5311 et seq., and the regulations enforced by the Office of Foreign Assets Control (OFAC), 31 C.F.R. Part 501, to prevent money laundering, terrorist financing, and other illicit financial activities. Our Anti-Money Laundering, Counter-Terrorist Financing, and Sanctions Compliance Program ("AML/CFT/Sanctions Program") is designed to ensure strict adherence to U.S. federal regulations, promote transparency, and maintain the integrity of the financial system. We implement robust compliance measures, including customer due diligence (CDD) as required under 31 C.F.R. § 1022.210, ongoing transaction monitoring per 31 C.F.R. § 1022.320, and sanctions screening in accordance with 31 C.F.R. Part 561, among other requirements. Additionally, we actively cooperate with regulatory authorities and law enforcement to uphold a secure and compliant trading environment.
Delulu provides an onchain platform for spot trading digital assets and liquidity facilitation in permitted jurisdictions. Our services are accessible via Delulu’s website, API, and mobile applications.
Disclosure: Trading is risky. The risk of loss in trading or holding crypto assets can be substantial. You should therefore carefully consider whether trading is suitable for you in light of your financial condition.
We acknowledge that U.S. regulatory bodies, including the Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Financial Crimes Enforcement Network (FinCEN), and state financial regulators, have adopted varied approaches to defining and regulating crypto assets. For the purposes of this platform, 'Crypto Asset' refers to cryptocurrencies, convertible virtual currencies, digital commodities, payment tokens, stablecoins, or any other virtual assets that do not qualify as 'securities' under the U.S. Securities Act of 1933 or as financial instruments under applicable federal law. As a trading platform, we view Bitcoin, Litecoin, and other alternative coins as crypto assets representing an emerging and innovative alternative asset class. These crypto assets are not fiat money or fiat currency, are not backed by any government or central bank, and accordingly, we do not classify them as traditional currency or money.
Restricted Locations: We do not offer services in the following jurisdictions, including but not limited to: North Korea, Syria, Iran, Cuba, Venezuela, Crimea, Luhansk, Donetsk and Russia.
We comply with all applicable U.S. federal and state laws and cooperate with law enforcement agencies to prevent illicit activity on our platform. If requested by authorized agencies, we may share customer information as permitted by law.
We have implemented a multi-layered, risk-based AML/CFT compliance program to detect and prevent money laundering, terrorist financing, and other illicit activities. Our approach includes robust customer identification, sanctions screening, transaction monitoring, and compliance oversight, ensuring strict adherence to U.S. regulatory requirements.
The first layer consists of a Customer Identification Program (CIP) designed to verify the identity of all users in compliance with FinCEN’s Know Your Customer (KYC) requirements. For institutional accounts, we require full beneficial ownership disclosure in accordance with FinCEN’s Customer Due Diligence (CDD) Rule, 31 C.F.R. § 1010.230.
The second layer involves sanctions screening and risk assessment. We screen all customers against the OFAC Specially Designated Nationals (SDN) List, the U.S. Department of State sanctions lists, and other applicable government watchlists. We may impose additional restrictions based on our risk assessment framework.
The third layer focuses on transaction monitoring and suspicious activity reporting (SARs). We continuously monitor transactions for unusual trading patterns and high-risk activities. If any suspicious activity is detected, we promptly file Suspicious Activity Reports (SARs) with FinCEN as required under 31 C.F.R. § 1022.320.
The fourth layer ensures compliance oversight and staff training. Our dedicated compliance team enforces AML policies, conducts internal audits, and ensures full regulatory adherence. Additionally, we provide ongoing AML training to employees to maintain awareness of emerging financial crime risks and regulatory updates.
Trading in crypto assets is considered high risk. Crypto assets such as bitcoin and litecoin are NOT backed by any government or central bank. The risk of loss in trading or holding crypto assets can be substantial. You should carefully consider whether interacting, holding, or trading crypto assets is suitable for you in light of your financial condition.
If you have any questions or require assistance with our customer due diligence controls, please contact our 24/7 customer support team via phone, chat, or email at [email protected].