The purpose of Aconix Ltd’s Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) policy is to identify, prevent, and mitigate any risks of Aconix Ltd being involved in illicit financial activities.

Financial institutions and related entities, such as cryptocurrency exchanges, are often targeted for money laundering and terrorist financing. AML regulations encompass laws and procedures designed to prevent criminals from disguising illicit funds as legitimate income. Terrorist financing refers to providing financial support to individuals or groups engaged in terrorism, including fundraising, fund usage, and financial arrangements.

Aconix Ltd diligently monitors activities that may indicate money laundering or terrorist financing. To comply with international and local regulations, Aconix Ltd has established internal procedures to prevent financial crimes, including money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery. The company takes appropriate action in response to any suspicious activity from its clients.

Compliance Measures
Aconix Ltd has appointed a Compliance Officer (pending) responsible for implementing the AML policy, which includes the following measures:

Verification Procedure
Before granting access to its services, Aconix Ltd requires customer identity verification to combat money laundering and terrorist financing. Legal requirements mandate financial institutions to collect, verify, and record identifying information from individuals and entities seeking to engage in transactions. Customers must provide their name, address, date of birth, and relevant details about themselves or associated entities.

Customers deemed higher risk may undergo enhanced due diligence, requiring additional documentation and extended verification times. Aconix Ltd reserves the right to conduct ongoing identity verification, particularly when a customer’s information changes or their activities appear suspicious. Updated documents may be requested, even if previously authenticated.

All collected customer identification data is handled in compliance with Aconix Ltd’s Privacy Policy and applicable regulations.

Risk Assessment
Aconix Ltd follows a risk-based approach to identify, assess, and mitigate risks related to money laundering and terrorist financing. Risk factors include:

1. Customer Risk:
Indicators of high-risk customers include discrepancies in identification documents, fictitious identities, stolen or counterfeit IDs, P.O. box addresses, past financial crimes, terrorist affiliations, wanted status, invalid contact details, and inconsistencies in legal entity documentation.

Politically Exposed Persons (PEPs) are also classified as higher risk. These include individuals holding or having held prominent public positions, such as heads of state, government ministers, members of parliament, high-ranking military officers, executives of state-owned enterprises, and senior officials of international organizations.

2. Country Risk:
The Anti-Money Laundering Directive enforces stricter due diligence for business relationships or transactions involving high-risk third countries. Additional information may be required regarding customer identity, beneficial ownership, sources of funds, transaction purpose, and senior management approval before engaging in such relationships.

Customer Activity Monitoring
Aconix Ltd continuously monitors customer activity to detect fraudulent or unlawful transactions. All transactions are reviewed, and any suspicious activity is thoroughly investigated. If necessary, such activities are reported to the relevant authorities, and additional measures may be taken to prevent financial crimes. Customers may be required to provide further documentation for suspicious transactions. Aconix Ltd reserves the right to suspend or terminate relationships with clients suspected of engaging in illegal activities.

Reporting Suspicious Activities
In accordance with its AML policy and legal obligations, Aconix Ltd reports suspicious activities to the relevant authorities when required. The company does not disclose details about such reports and will not respond to inquiries related to them.

Staff Training and Internal Controls

Aconix Ltd ensures that all relevant staff are regularly trained in anti-money laundering and counter-terrorist financing obligations. Training includes recognizing suspicious activities, understanding legal responsibilities, and following internal procedures. In addition, Aconix Ltd performs periodic internal audits and assurance testing to evaluate the effectiveness of its AML/CTF program and to ensure continuous compliance with applicable laws and regulations.

Sanctions and PEP Screening

Aconix Ltd conducts sanctions and politically exposed persons (PEP) screening at onboarding and on an ongoing basis. These screenings are automated and utilize reputable compliance databases that aggregate information from global sanctions lists (e.g., United Nations, OFAC, European Union) and international PEP registries. Screening is performed at onboarding and routinely thereafter to capture any changes in customer status.

FATF Compliance

Where applicable, Aconix Ltd complies with the Financial Action Task Force (FATF) Travel Rule by ensuring that required originator and beneficiary information is collected, verified, and transmitted during virtual asset transfers that meet or exceed the applicable thresholds.

Record Keeping

In accordance with legal obligations, Aconix Ltd retains all relevant records, including customer identification documents, transaction data, and communications related to suspicious activities, for a minimum of five (5) years from the date of the transaction or the end of the business relationship, whichever is later.

Policy Review and Update

This AML/CTF policy is reviewed at least once annually, or more frequently in response to significant regulatory changes, new risk assessments, or changes in operational practices. Updates are documented and approved by the Compliance Officer (pending) and senior management.