Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Last updated: January 2025

Nytrix Vault AI is committed to preventing money laundering, terrorist financing, and other financial crimes. This policy outlines our procedures for customer due diligence and compliance with applicable AML regulations.

1. Purpose

This AML/KYC Policy establishes the framework for identifying, assessing, and mitigating risks related to money laundering, terrorist financing, fraud, and other illicit activities on the Nytrix Vault AI Platform.

2. Know Your Customer (KYC) Procedures

2.1 Identity Verification

All users must complete identity verification before accessing trading features. This includes:

• Tier 1 — Basic Verification: Full name, date of birth, email address, phone number, and country of residence
• Tier 2 — Enhanced Verification: Government-issued photo ID (passport, national ID, or driver's licence) and proof of residential address (utility bill, bank statement, or official correspondence dated within 3 months)
• Tier 3 — Additional Due Diligence: Source of funds documentation, additional identification, or video verification (for high-value accounts or higher-risk profiles)

2.2 Ongoing Monitoring

Nytrix Vault AI performs continuous transaction monitoring to detect suspicious patterns, including:

• Unusually large or frequent transactions
• Transactions inconsistent with the user's stated profile or activity history
• Rapid movement of funds without trading activity
• Structuring transactions to avoid reporting thresholds

3. Risk-Based Approach

We apply a risk-based approach to due diligence, with enhanced measures for:

• Politically Exposed Persons (PEPs) and their associates
• Users from higher-risk jurisdictions
• Complex or unusual transaction patterns
• High-value accounts exceeding defined thresholds

4. Suspicious Activity Reporting

Where Nytrix Vault AI identifies suspicious activity, we will file Suspicious Activity Reports (SARs) or equivalent reports with the relevant Financial Intelligence Unit (FIU) as required by applicable law. We will not inform the user that a report has been filed.

5. Sanctions Screening

All users are screened against international sanctions lists including OFAC (US), EU, UN, and other applicable sanctions regimes. Matches result in account restrictions pending further investigation.

6. Record Keeping

KYC documents, transaction records, and due diligence materials are retained for a minimum of 5 years after account closure, in compliance with applicable regulations.

7. Employee Training

All Nytrix Vault AI staff involved in customer-facing or compliance functions receive regular AML/KYC training covering regulatory updates, red flag indicators, and reporting procedures.

8. Non-Compliance

Failure to complete KYC verification or provide requested documentation may result in account restrictions, suspension, or closure. Nytrix Vault AI reserves the right to refuse service to any individual who fails to meet our compliance standards.

9. Contact

Compliance inquiries: [email protected]