Anti-Money Laundering Policy

1 Purpose and our commitment

Money laundering is the process of making money that comes from crime look as if it came from a lawful source. Services that hold customer balances and move value, like ours, are exactly where criminals try to do this, which is why the law places duties on us and why this Policy exists.

Our position is simple: we do not want criminal money on MarketsMill ™, at any price. We would rather decline a deposit, lose a customer, or give up revenue than let the Services be used to launder money, finance terrorism, or evade sanctions. This commitment is owned by senior management, it binds everyone who works on the Platform, and no commercial target overrides it.

This Policy is our public statement of that commitment and of the checks you can expect as a user. It summarises the program we operate. The detailed internal procedures that implement it, including specific thresholds and review rules, are deliberately not published, because publishing them would show bad actors exactly how to avoid them.

2 Who this Policy applies to

This Policy applies to every visitor and every account holder, and to all activity on the Services: deposits by any supported method, withdrawals, P2P Transfers between users, the Investment Products (Auto-Earn, Dual Investment, Institutional Connect, and Prime Growth), voucher purchases, and the referral and commission program. It also binds our own staff, contractors, and the service providers who act for us.

Capitalised words that are not defined here have the meaning given in the Terms of Service. Complying with this Policy is a continuing condition of holding an account, not a one-time check at sign-up.

3 Key terms used in this Policy

Money laundering means disguising the proceeds of crime as legitimate funds. It is often described in three stages: placement, where criminal money enters the financial system; layering, where it is moved around to hide its trail; and integration, where it re-emerges looking clean.

Terrorist financing means providing or collecting funds, from any source including lawful ones, intending or knowing that they will be used to support terrorism.

Sanctions are measures imposed by governments and international bodies that restrict dealings with listed persons, entities, and places.

KYC ("know your customer") and customer due diligence mean the checks we run to identify you and to understand your use of the Services.

Enhanced due diligence means the deeper checks we apply where the risk is higher.

Source of funds means where the money in a specific transaction came from. Source of wealth means how a person's overall assets were built up.

Politically exposed person or PEP means a person who holds or has held a prominent public function, together with their close family members and known associates.

Suspicious activity report means a report that regulated businesses must file with the authorities when they know or suspect that funds are linked to crime.

4 The laws and standards we follow

This program is designed to follow the international standards set by the Financial Action Task Force (FATF) and the anti-money-laundering and counter-terrorist-financing laws that apply in the places where we operate. Where a local law is stricter than this Policy, the stricter rule is applied.

State here, accurately, the operating entity's regulatory position: each licence or registration it holds, for example as a virtual-asset service provider, the authority that supervises it, and the registration numbers. If authorisation has not yet been obtained, this Policy must not suggest otherwise, and legal advice should be taken on whether and where the Services can lawfully be offered.

We do not claim to be a bank, an e-money institution, or a licensed investment firm, and nothing in this Policy is a representation of any regulatory status beyond the one stated above.

5 Who is responsible for this program

Overall responsibility for this Policy sits with our senior management. Day to day, the program is run by our designated compliance officer, name or role of the appointed compliance officer or money laundering reporting officer, who can be reached at compliance contact email.

The compliance officer's duties include: keeping this Policy and the internal procedures behind it current; reviewing activity that our controls or our team flag; deciding whether a report must be made to the authorities, and making it; answering lawful requests from law enforcement and regulators; and making sure the people who operate the Platform are trained as Section 16 describes.

6 Our risk-based approach

We take a risk-based approach, which is what the FATF standards require: the checks applied to a customer or a transaction are proportionate to the risk it presents. Everyone gets the baseline checks in Section 7. Higher risk brings the deeper measures in Sections 8 and 9.

The factors we weigh include the size, speed, and pattern of activity on an account, how that activity compares with what we know about the customer, the deposit method used, the countries involved, how clear the source of funds is, the customer's verification history, and unusual behaviour inside the referral network, such as circular transfers or clusters of accounts acting together.

7 Identity verification (KYC)

Identity verification is mandatory. It is a legal obligation, not a marketing step. When you verify, you provide your full legal name and a government-issued photo identity document, and you complete a photo or liveness check. Where the risk or the law requires it, we ask for further details, such as your date of birth, residential address, and nationality. Specialist identity-verification providers may be used to check that a document is genuine, as described in our Privacy Policy.

You must complete and pass verification before you can withdraw funds. Access to features is staged on your verification status, and we may restrict deposits, investing, P2P Transfers, or commissions until the relevant checks are complete. We may re-verify you, or ask for updated documents, at any time while your account is open.

The documents and details you give us must be genuine, current, and your own. If you refuse or fail verification, your account and any pending activity may be restricted, suspended, or closed, and funds may be held until verification is completed, to the extent the law allows. Verification holds are never used as a penalty, and held funds are never treated as our revenue.

8 Enhanced due diligence

Some situations carry more risk and receive more scrutiny. We apply enhanced due diligence where, for example: activity is unusually large or fast for the account; the pattern of deposits, transfers, or withdrawals does not fit what we know about the customer; a customer or transaction is connected to a higher-risk country; the customer is a politically exposed person; the source of funds is unclear; or accounts in a referral network appear to be acting in concert.

Enhanced due diligence can include: asking for evidence of source of funds or source of wealth, such as an exchange statement, a bank record, or proof of a sale; asking further questions about the purpose of the activity; senior review of the relationship; and tighter limits or holds while the review is open. If the answers do not resolve the concern, we act under Section 13.

9 Source-of-funds reviews

We may ask you to verify the source of a deposit, before it is credited or at any point afterwards. What we ask depends on how the deposit was funded: for a deposit from an exchange, we ask which exchange and for the transaction reference; for a deposit from a private wallet, we ask about the wallet and the transfer; for activity funded from your existing Platform balance or from a voucher, we ask how that balance or voucher was obtained, including who provided it.

You are expected to answer accurately and, where asked, to provide evidence such as a screenshot, a statement, or an on-chain transaction reference. While a source-of-funds review is open, the deposit, or the features connected to it, may be paused. If a review is rejected, you can appeal the decision through the Platform and discuss it with our team, and the appeal is decided by a person, not automatically.

Deposit only funds that are yours. If a review shows that funds belong to someone else, came from crime, or cannot be explained, the deposit may be declined or returned where that is lawful, and Section 13 applies.

10 Sanctions and restricted places

The Services are not offered to, and may not be used by, residents, nationals, or persons located in a restricted place. That covers places where we are not authorised or choose not to operate, and places under comprehensive sanctions or embargoes. At the time of writing, comprehensively sanctioned places commonly include Cuba, Iran, North Korea, and the Crimea, Donetsk, and Luhansk regions. The list changes, and the current list is kept on a linked page rather than frozen into this document.

You confirm that you are not a sanctioned or restricted person, that you are not owned or controlled 50% or more by such persons, and that you are not acting for one. We check customers, and where relevant transactions, against applicable sanctions and watch lists, such as the OFAC, UN, EU, and UK lists, when you join and on an ongoing basis. You must not use a VPN, a proxy, or false location or residence details to get around geographic restrictions, and you must tell us if your sanctions status changes.

A confirmed or potential match can lead to a hold, a rejected transaction, blocked funds, an account freeze, or a report. Blocked funds may have to be held, or handed to the authorities, rather than returned, where the law requires it.

11 Transaction monitoring and account controls

Prevention on MarketsMill ™ is built into how the Platform works, and it is backed by review from our team:

• access to features is staged on your verification status, and limits can vary with it;
• deposits are credited only after the required network confirmations, and some deposit methods are reviewed by our team before they are credited;
• deposits can be subject to the source-of-funds reviews described in Section 9;
• cryptocurrency withdrawals can be sent only to an address saved on your account, and a security hold can apply when a newly added address is first used;
• withdrawal requests are reviewed before they are processed, and a one-time code is required to authorise them;
• an account can be locked so that nothing leaves it while a concern is investigated;
• sign-ins, sessions, and devices are tracked to detect account takeover; and
• actions taken by our own staff on the Platform are recorded in an internal log, so that decisions can be reviewed afterwards.

On top of these controls, we monitor activity for patterns associated with laundering: deposits split into many smaller amounts, funds that arrive and leave quickly with no genuine use of the products, circular transfers between related accounts, and referral commissions generated by manufactured volume. Unusual activity can lead to questions, holds, enhanced due diligence, or the steps in Section 13.

12 Activities we prohibit

You must not use the Services for or in connection with:

• money laundering, terrorist or proliferation financing, sanctions evasion, or moving the proceeds of any crime;
• depositing, holding, or moving funds that belong to an undisclosed third party, or running an unlicensed money-service or exchange business through your account;
• funds that have passed through mixers, tumblers, or other tools whose purpose is to hide their origin;
• structuring, that is, splitting deposits, withdrawals, or transfers into smaller amounts to avoid thresholds, reviews, or reporting;
• creating multiple or fake accounts, using false identity details, or opening a new account to get around a hold, limit, suspension, or closure; or
• manufactured or circular activity in the referral program, including funding another person's account to trigger commissions.

This list is tied to genuine legal and integrity risks. Ordinary, lawful use of the Services is never treated as a breach of this Policy.

13 Holds, declined transactions, and reports

We may pause, hold, decline, or reverse a transaction, or freeze, restrict, suspend, or close an account, only on defined grounds: a pending verification or source-of-funds review; suspected fraud, money laundering, terrorist financing, or a breach of this Policy or the Terms; a sanctions match; a legal or regulatory requirement or an order from a court or authority; or a reversed or charged-back deposit. We act proportionately, keep any hold no wider or longer than necessary, and lift it promptly once the concern is resolved or we are legally permitted to.

Where the law requires it, we report suspicious activity to the financial-intelligence unit or other authority with jurisdiction over the operating entity and comply with related orders. The law may prohibit us from telling you that a report has been made or considered, or from explaining exactly why a transaction was declined or an account was frozen. That silence is a legal limit that binds regulated businesses, not a discretionary refusal to communicate, and we share as much as we are lawfully allowed to.

We cooperate with law enforcement and regulators on valid, lawful requests, as our Privacy Policy describes. We do not keep, forfeit, or absorb your funds as a penalty or as revenue. On closure, any remaining lawful balance is returned to you once legitimate holds and legal obligations are resolved, net only of amounts we are required to withhold or to hand to the authorities.

14 Record keeping

We keep the records this program produces: identity-verification records and the documents you upload; transaction records, including deposit and withdrawal addresses and on-chain references; source-of-funds answers and evidence; the notes and outcomes of reviews and appeals; and, where the law allows, copies of reports made to the authorities.

These records are kept while your account is open, and after it closes for as long as the law requires, commonly at least five years. Confirm the exact retention periods that apply in the operating jurisdiction, and align the Privacy Policy's retention section with them. They are handled as our Privacy Policy describes, and because keeping them is a legal obligation, they may be retained even if you ask for your data to be deleted.

15 Your obligations as a user

You keep this program working by doing a few simple things:

• give information that is true, current, and complete, at registration and afterwards;
• deposit and use only funds that are lawfully yours;
• respond promptly and honestly when we ask you to verify your identity or the source of funds;
• keep your contact details current so that we can reach you;
• do not let anyone else use your account, and do not use anyone else's; and
• tell us if you believe an account or a transaction on the Platform is being used for crime.

Refusing to cooperate with a check is itself a ground for restriction under Section 13, even where nothing else is wrong, because a check we cannot complete is a risk we cannot clear.

16 Training and review of this program

The people who operate the Platform receive training on this Policy: how laundering appears on a service like ours, the checks this document describes, and what to do when something looks wrong, including who to escalate it to. State the training arrangements actually in place, who receives them, and how often they are refreshed.

This Policy and the program behind it are reviewed state the review cadence, commonly at least once a year, and additionally whenever the law, our products, or our risks change materially. State whether the program is subject to independent review or audit, and by whom.

17 Changes to this Policy

We may update this Policy as laws, our products, or our risks change. When we make a material change, we will update the version and date at the top of this page and give notice as the Terms of Service describe. The version published on this page is the one that applies.

18 How to contact us

For questions about this Policy, or about a check running on your account, contact support through the help section of the app or at [email protected]. For compliance matters, contact our compliance officer at compliance contact email. For legal or regulatory notices, write to Operating Entity legal name at registered address. Requests from law enforcement or regulators should state their legal basis and are handled by the compliance officer.