AML and Counter Terrorist Financing Policy

We will not knowingly move criminal proceeds, and we will refuse business rather than accept a transaction we cannot explain. That position costs us orders and it is not negotiable.

Verification scales with what is being asked of us.

• Orders without an account are capped and require a name, an email address and a phone number.
• Account holders provide a government photo ID, a selfie and a proof of address.
• Company accounts additionally provide registration documents and a declaration of beneficial ownership.
• Enhanced due diligence applies to politically exposed persons and to sustained high volume.

Every order is screened against sanctions lists, and every wallet address is screened against chain analytics before a release. Patterns that suggest structuring, layering or funding by third parties are escalated to a human, not to a rule.

Where a transfer falls within the Travel Rule, we exchange originator and beneficiary information with the counterparty institution before settling.

Suspicious activity is reported to the competent financial intelligence unit. We are not permitted to tell you when we have made a report, and we will not.

Some things end the relationship rather than delay it.

• Payment from anyone other than the account holder.
• Addresses linked to sanctioned entities, ransomware, mixers or known fraud.
• Any attempt to break an order into smaller ones to stay under a threshold.
• Refusal to explain the source of funds when we are required to ask.