First Party Transfer(Me-to-Me) Policy

1. Inflow of Funds (Fiat and Crypto)

SuisseBase™️ accepts fiat and crypto deposits from clients who have undergone full KYC/AML onboarding. All inflows are strictly governed by a “Me-to-Me” policy, ensuring that funds originate solely from accounts or wallets registered under the verified client’s legal name.

Fiat Deposits:

• Clients may fund their accounts via:

• SEPA, SWIFT, or local rails depending on the currency and location.

• Deposits are processed through our regulated partner banks and virtual IBAN issuers.

• All fiat deposits are screened for origin, purpose, and compliance via automated and manual procedures.

Crypto Deposits:

• Only permitted from self-custodial wallets owned and verified by the client.

• Wallet ownership is validated using WalletConnect, signed message proofs, or on-chain traceability.

• Crypto transactions are pre-screened using blockchain forensics tools before acceptance.

• SuisseBase™️ does not accept deposits from unverified or third-party wallets.

2. Outflow of Funds

Fiat Withdrawals:

• Executed only to the same-name bank account from which the funds were originally deposited or another verified “Me-to-Me” account.

• Funds are transferred via the appropriate banking rails in the respective currency.

• Prior to execution, each request is screened against transactional history, risk profile, and sanctions lists.

Crypto Withdrawals:

• Allowed only to the verified self-custodial wallet previously whitelisted during onboarding.

• Withdrawals are delayed by a cool-down period (24-48 hours in high-risk cases) as an internal fraud mitigation strategy.

• Funds are checked again via blockchain screening tools prior to release.

3. Adherence to the Travel Rule

SuisseBase™️ is fully compliant with FATF Travel Rule obligations and applies Travel Rule procedures to all relevant virtual asset transfers:

• For outbound crypto transfers above the regulatory threshold, SuisseBase™️ collects and transmits:

• Originator and beneficiary name

• Wallet addresses

• Unique client identifiers (KYC-verified)

• Information is securely exchanged with counterparties using integrated Travel Rule solution providers or through encrypted secure messaging, in line with FINMA expectations and FATF guidance.

• For inbound crypto transfers, SuisseBase™️ requests equivalent originator information and may reject or hold funds until counterparties provide compliant data.

The term “Me-to-Me” is an industry-adopted shorthand, particularly used in compliance and payments contexts, to describe transfers where the sender and the beneficiary are the same legal person—i.e., the account holder is transferring funds to or from their own account or wallet, not to third parties.

While it’s not a formal acronym defined by regulatory bodies like FATF or FINMA, it is commonly used in compliance circles, fintechs, and banking partners to distinguish:

• “Me-to-Me” transactions – allowed under most VASP compliance frameworks (i.e., user deposits and withdrawals from/to accounts or wallets in their own name).

• “Third-party” transactions – which raise risk flags and are generally restricted or prohibited unless specifically justified and documented.

In your case, at SuisseBase™️, you apply the Me-to-Me standard operationally and as part of your risk mitigation framework (as mentioned in your SOPs and onboarding policies), meaning:

Funds must always originate from or be withdrawn to accounts/wallets owned and controlled by the verified client. No third-party deposits or withdrawals are permitted.