AML & Compliance Policy

1. Policy objective

Legacy NFTY is committed to preventing the Platform from being used for money laundering, terrorist financing, fraud, sanctions evasion, proliferation financing, corruption, theft or other prohibited activity.

This AML & Compliance Policy describes the risk-based measures that may be applied to accounts, transactions, referrals and administrator-managed plans. It does not limit any additional review required by applicable law, service providers or Platform risk controls.

2. Scope

This Policy applies to applicants, members, beneficial owners, authorised representatives, counterparties and any person whose information or activity is connected to use of the Platform.

3. Customer identification and verification

Legacy NFTY may require information and documents sufficient to identify and verify a user. This may include full legal name, date of birth, nationality, residential address, phone number, email address, government identification and a live or additional verification step.

For an organisation, information may include legal name, registration records, business activity, registered address, directors, authorised representatives and ultimate beneficial owners.

4. Accuracy and authenticity

All information must be accurate, current and authentic. Altered documents, borrowed identities, false addresses, nominee arrangements intended to conceal ownership or repeated accounts created to avoid controls are prohibited.

Legacy NFTY may use internal review, public records, service providers or additional evidence to evaluate information.

5. Source of funds and source of wealth

Members may be asked to explain and evidence the origin of funds or overall wealth, particularly for higher-value, unusual, complex or higher-risk activity. Evidence may include transaction records, income information, sale documents, business records or other relevant material.

Failure to provide satisfactory evidence may result in delay, restriction, rejection or account closure.

6. Enhanced due diligence

Enhanced review may apply where risk is higher, including large or unusual activity, complex ownership, high-risk jurisdictions, politically exposed persons, adverse information, sanctions exposure, privacy-enhancing activity or inconsistent account behaviour.

Enhanced due diligence may involve additional documents, explanations, approval levels, monitoring, limits or review of connected accounts and counterparties.

7. Sanctions and prohibited locations

Legacy NFTY may screen users and activity against sanctions, watchlists and other risk information. Accounts or transactions associated with prohibited persons, entities, locations or activity may be blocked, rejected, restricted or reported where required.

Users must not use tools, intermediaries or false information to conceal their location or sanctions exposure.

8. Transaction monitoring

Account and blockchain activity may be reviewed for patterns that are unusual, inconsistent with profile information or associated with known risk indicators. Examples may include rapid movement of funds, structuring, unexplained third-party transfers, multiple related accounts, repeated reversals, unusual referral patterns or evidence that does not match a transaction.

Monitoring may be automated, manual or supported by external services. A review does not itself mean wrongdoing has occurred.

9. Prohibited activity

• Money laundering, terrorist financing or sanctions evasion.
• Fraud, scams, theft, ransomware, extortion or stolen funds.
• Human trafficking, exploitation or prohibited goods and services.
• Corruption, bribery, embezzlement or misuse of public funds.
• Use of mixers, obfuscation or complex routing intended to conceal unlawful origin.
• Use of another person's identity, account or wallet without lawful authority.
• Creation of duplicate or coordinated accounts to avoid controls or obtain rewards.
• False transaction evidence, altered screenshots or misleading explanations.

10. Holds, restrictions and rejection

Legacy NFTY may delay, hold, restrict, reject or cancel an account action when review is required, information is incomplete, a risk indicator is present, account security is uncertain or processing would create legal or operational risk.

Where permitted, additional information may be requested. Legacy NFTY may be unable to disclose specific monitoring criteria, reports or reasons when doing so would compromise security or violate law.

11. Suspicious activity and reporting

When legally required or reasonably necessary, Legacy NFTY may preserve information, cooperate with authorities, respond to lawful requests or report suspicious activity. Users may not be informed when disclosure is prohibited.

12. Record retention

Identity, transaction, communication, review and decision records may be retained for the period required or justified by applicable law, risk management, dispute handling and legal claims.

13. Ongoing monitoring and re-verification

Compliance is not limited to registration. Legacy NFTY may update risk assessments, request refreshed documents, review changes in ownership or profile information and repeat checks during the account relationship.

14. Referral and connected-account risk

Referral relationships may be reviewed for self-referrals, circular structures, duplicate identities, coordinated deposits, reward manipulation or other suspicious patterns. Ineligible rewards may be withheld, cancelled or reversed.

15. User responsibilities

Users must provide accurate information promptly, respond to reasonable requests, maintain records supporting their activity and avoid sending funds on behalf of unknown third parties. Users should not accept instructions from people claiming they can bypass Platform review.

16. Privacy and confidentiality

Compliance information is handled according to the Privacy Policy and access controls. Information may be shared with service providers, advisers or authorities when reasonably necessary and legally permitted.

17. Policy changes

This Policy may be updated as laws, risk indicators, Platform features and operational standards evolve. Continued use may be subject to the current published version.

18. Contact

Compliance questions should be submitted through the official Legacy NFTY contact channel. Do not send passwords, OTPs, authenticator codes, private keys or seed phrases.