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Anti-Money Laundering Policy

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ComplianceEffective Date: 31st August, 2026Last Updated: 31st August, 2026

Anti-Money Laundering Policy

Acceliqs is committed to building a secure, transparent, and responsible technology ecosystem supported by appropriate financial crime prevention and compliance measures.

Company

Acceliqs

Policy

AML / CTF

Status

Compliance Framework

01

Introduction

Acceliqs is committed to maintaining a secure, transparent, and responsible technology ecosystem. As our platform develops across artificial intelligence, automated trading technology, digital assets, blockchain infrastructure, exchange services, staking, and gamified ecosystem experiences, we recognize the importance of implementing appropriate measures designed to prevent the misuse of our products and services for money laundering, terrorist financing, fraud, sanctions evasion, or other illicit financial activity.

This Anti-Money Laundering ("AML") Policy describes the principles and procedures adopted by Acceliqs to help identify, assess, monitor, and report suspicious activities where required by applicable laws and regulations.

Acceliqs is committed to developing and operating its services in accordance with applicable Anti-Money Laundering ("AML"), Counter-Terrorist Financing ("CTF"), sanctions, and financial crime prevention requirements in the jurisdictions where it operates or provides regulated services.

This Policy should be read together with our:

  • Terms and Conditions
  • Privacy Policy
  • Risk Disclosure
  • Know Your Customer ("KYC") procedures
  • Sanctions Compliance procedures
  • Fraud Prevention procedures
  • Any other applicable compliance policies implemented by Acceliqs
02

Purpose of This Policy

The purpose of this AML Policy is to establish a framework designed to help Acceliqs:

  • Prevent the use of its platform for money laundering or terrorist financing
  • Identify customers and verify customer information where required
  • Assess financial crime risks associated with customers, transactions, products, and jurisdictions
  • Monitor customer activity and transactions for unusual or suspicious behavior
  • Conduct enhanced due diligence where higher risks are identified
  • Screen relevant parties against applicable sanctions and restricted-party lists
  • Maintain appropriate records
  • Escalate and investigate suspicious activity
  • Cooperate with competent regulatory, law enforcement, and government authorities where legally required
  • Promote a culture of compliance across the Acceliqs ecosystem
  • Evolve compliance measures as the platform introduces new products, services, jurisdictions, and technologies
03

Scope

This AML Policy applies, where relevant, to users and participants interacting with Acceliqs products and services.

Depending on the services available at a particular time, this may include:

  • Users of Acceliqs' AI-powered trading technologies
  • Customers accessing automated trading tools
  • Users interacting with digital asset services
  • Participants in future exchange products
  • Holders or users of ecosystem-related digital assets
  • Participants in staking programs
  • Participants in gamified ecosystem products
  • Business partners and counterparties
  • Vendors and service providers where appropriate
  • Employees, contractors, officers, and representatives of Acceliqs
04

Our Commitment to Financial Crime Prevention

Acceliqs does not knowingly permit its products, services, infrastructure, or technology to be used for activities involving:

Acceliqs may take reasonable and proportionate measures to identify and prevent suspicious or prohibited activity.

Where necessary, Acceliqs reserves the right to take appropriate compliance action.

Additional informationAcceliqs may request additional information where necessary.
Identity verificationUsers may be required to complete identity verification procedures.
Source of fundsAcceliqs may request evidence supporting the origin of funds.
Source of wealthAcceliqs may request evidence supporting the origin of a customer's wealth.
Service restrictionsAccess to certain products or transactions may be restricted, delayed, or rejected.
Account actionAccounts may be suspended or terminated where appropriate.
Regulatory reportingSuspicious activity may be reported to competent authorities where required by law.
  • Money laundering
  • Terrorist financing
  • Fraud
  • Sanctions evasion
  • Proceeds of criminal activity
  • Identity theft
  • Financial deception
  • Market manipulation
  • Bribery and corruption
  • Illicit transfer of funds or digital assets
  • Financing of prohibited activities
  • Any other unlawful financial activity
05

Understanding Money Laundering

Money laundering generally refers to processes used to disguise or conceal the origin, ownership, movement, or control of funds or assets derived from criminal activity.

Although money laundering methods vary, they are often described in three general stages.

5.1

Placement

Placement involves introducing funds or assets derived from unlawful activity into a financial system.

Examples may include attempts to:

  • Deposit suspicious funds
  • Convert illicit proceeds into digital assets
  • Use multiple accounts to move funds
  • Break transactions into smaller amounts to avoid detection
5.2

Layering

Layering involves conducting multiple transactions intended to obscure the origin or ownership of funds.

Examples may include:

  • Repeated transfers between accounts
  • Complex digital asset transactions
  • Transfers involving multiple wallets
  • Rapid movement of assets between platforms
  • Transactions with no apparent economic purpose
  • Attempts to obscure the source of funds through multiple intermediaries
5.3

Integration

Integration occurs when funds that originated from unlawful activity are introduced into the legitimate economy in a manner intended to make them appear legitimate.

Acceliqs recognizes that financial crime can involve complex structures and evolving technologies. For this reason, our compliance approach may be updated as risks, regulations, and technological environments change.

06

Risk-Based Approach

Acceliqs adopts a risk-based approach to AML compliance.

This means that the level of review and monitoring applied may depend on the level of risk associated with a customer, transaction, product, service, or jurisdiction.

Factors considered when assessing risk may include:

Higher-risk situations may require additional verification and enhanced due diligence.

  • Customer profile
  • Geographic location
  • Nature of the product or service
  • Transaction size
  • Transaction frequency
  • Source of funds
  • Source of wealth
  • Digital asset transaction history where applicable
  • Use of third-party payment methods
  • Politically exposed person status
  • Sanctions exposure
  • Adverse media or other credible risk indicators
  • Other factors relevant to financial crime risk
07

Customer Due Diligence (CDD)

Where required by applicable law, regulation, or internal risk assessment, Acceliqs may conduct Customer Due Diligence ("CDD") before providing access to certain products or services.

CDD procedures may include collecting and verifying information such as:

The type and level of verification may depend on the nature of the service being provided and the level of risk identified.

Acceliqs may use internal systems or approved third-party service providers to assist with identity verification.

  • Full legal name
  • Date of birth
  • Residential address
  • Nationality
  • Government-issued identification
  • Contact information
  • Proof of address
  • Tax residency information where applicable
  • Other information reasonably required to verify identity
08

Know Your Customer (KYC)

Know Your Customer ("KYC") procedures form an important component of Acceliqs' approach to financial crime prevention.

KYC processes may be required before users can access certain products, services, transaction limits, or ecosystem features.

Depending on applicable requirements, users may be required to provide:

Acceliqs reserves the right to reject or suspend verification where information appears incomplete, inaccurate, misleading, fraudulent, or inconsistent.

  • Valid government-issued identification
  • Proof of residential address
  • A live facial verification or liveness check
  • Additional documentation supporting identity verification
  • Other information reasonably required for compliance purposes
09

Enhanced Due Diligence (EDD)

Enhanced Due Diligence ("EDD") may be applied when a customer, transaction, jurisdiction, or activity presents a higher level of potential financial crime risk.

EDD may include additional measures such as:

Enhanced Due Diligence may be applied to customers classified as high risk.

  • Requesting additional identification documents
  • Verifying source of funds
  • Verifying source of wealth
  • Conducting additional transaction monitoring
  • Reviewing the purpose of a transaction
  • Obtaining additional information regarding beneficial ownership
  • Conducting additional sanctions screening
  • Reviewing publicly available adverse information
  • Requiring enhanced internal approval before establishing or continuing a relationship
10

Politically Exposed Persons

A Politically Exposed Person ("PEP") is generally an individual who has been entrusted with a prominent public function.

PEPs may include, depending on applicable law:

Being classified as a PEP does not automatically mean that a person is involved in illegal activity.

However, relationships involving PEPs may present additional financial crime risks and may therefore be subject to Enhanced Due Diligence.

  • Senior government officials
  • Senior political figures
  • Senior judicial officials
  • Senior military officials
  • Executives of state-owned enterprises
  • Senior officials of international organizations
  • Family members or close associates of such individuals where applicable
11

Sanctions Compliance

Acceliqs is committed to complying with applicable economic and financial sanctions laws and regulations.

Where appropriate, Acceliqs may screen users, counterparties, transactions, and other relevant parties against applicable sanctions and restricted-party lists.

Acceliqs may restrict or prohibit access to its products or services where an individual or entity:

Acceliqs may take any action required by applicable law, including restricting accounts, rejecting transactions, freezing assets where legally required, or reporting information to competent authorities.

  • Appears on an applicable sanctions list
  • Is located in a jurisdiction subject to applicable restrictions
  • Is owned or controlled by a sanctioned person or entity where relevant
  • Is suspected of attempting to evade sanctions
  • Otherwise presents an unacceptable sanctions-related risk
12

Transaction Monitoring

Acceliqs may implement monitoring systems designed to identify unusual, suspicious, or potentially high-risk activity.

Monitoring may consider factors including:

Where suspicious activity is identified, Acceliqs may conduct additional reviews.

  • Transaction frequency
  • Transaction size
  • Transaction patterns
  • Rapid movement of assets
  • Unusual account activity
  • Inconsistent user behavior
  • Transactions without an apparent economic purpose
  • Activity involving high-risk jurisdictions
  • Attempts to circumvent transaction limits
  • Multiple accounts associated with the same individual
  • Sudden changes in transaction behavior
  • Other indicators of potentially suspicious activity
13

Digital Asset Monitoring

As parts of the Acceliqs ecosystem may involve blockchain technology and digital assets, additional monitoring measures may be implemented where appropriate.

Digital asset-related reviews may consider:

Acceliqs may use blockchain analytics technologies or specialized compliance providers where appropriate.

  • Blockchain transaction history
  • Wallet activity
  • Transaction patterns
  • Exposure to high-risk wallet addresses
  • Interactions with sanctioned addresses
  • Use of anonymization technologies where relevant
  • Exposure to known illicit activity
  • Rapid transfers between multiple wallets
  • Other blockchain-based financial crime indicators
14

Source of Funds and Source of Wealth

In certain circumstances, Acceliqs may request information regarding a customer's source of funds or source of wealth.

Source of funds refers to the origin of the funds involved in a particular transaction.

Source of wealth refers more broadly to how an individual accumulated their overall financial resources.

Supporting documentation may include, where appropriate:

Failure to provide satisfactory information may result in restrictions being applied to an account or transaction.

  • Employment records
  • Salary statements
  • Bank statements
  • Business ownership documentation
  • Investment records
  • Tax documentation
  • Sale agreements
  • Inheritance documentation
  • Other credible evidence supporting the origin of funds or assets
15

Suspicious Activity

Acceliqs may investigate activity that appears unusual or inconsistent with expected customer behavior.

Examples of potentially suspicious activity may include:

The presence of one indicator does not necessarily mean that illegal activity has occurred.

However, Acceliqs may review activity where one or more risk indicators are identified.

  • Providing false or misleading identification information
  • Attempting to use another person's identity
  • Creating multiple accounts without a legitimate reason
  • Structuring transactions to avoid verification requirements
  • Conducting transactions with no apparent economic purpose
  • Rapidly moving funds through multiple accounts or wallets
  • Refusing to provide requested information
  • Providing inconsistent explanations regarding transactions
  • Attempting to circumvent geographic restrictions
  • Using technology designed to conceal location or identity for prohibited purposes
  • Activity linked to known illicit addresses or entities
  • Any activity reasonably suspected to involve financial crime
16

Reporting of Suspicious Activity

Where required by applicable law, Acceliqs may report suspicious activity to relevant government agencies, financial intelligence units, regulators, or law enforcement authorities.

Acceliqs may also cooperate with competent authorities where legally required.

Users may not be informed about certain investigations, reports, or compliance actions where disclosure is prohibited by law.

17

Prohibited Activities

Users may not use Acceliqs products or services for activities involving:

Attempting to use the Acceliqs ecosystem for prohibited activities may result in immediate action, including account suspension or termination.

  • Money laundering
  • Terrorist financing
  • Fraud
  • Identity theft
  • Financial scams
  • Sanctions evasion
  • Bribery or corruption
  • Market manipulation
  • Financing of illegal activities
  • Concealment of criminal proceeds
  • Use of stolen funds or assets
  • Operation of fraudulent investment schemes
  • Any activity prohibited by applicable law
18

Geographic Restrictions

Certain products or services may not be available in all countries or jurisdictions.

Acceliqs may restrict access to users located in jurisdictions where:

Users are responsible for ensuring that their use of Acceliqs products and services is lawful in their jurisdiction.

  • Applicable laws prohibit the service
  • Regulatory requirements cannot reasonably be satisfied
  • Economic sanctions apply
  • Financial crime risks are considered unacceptably high
  • Other legal or compliance restrictions apply
19

Record Keeping

Acceliqs may retain relevant records for periods required by applicable law or regulation.

Records may include:

Records will be retained and handled in accordance with applicable privacy and data protection laws.

  • Customer identification information
  • Verification records
  • Transaction information
  • Compliance reviews
  • Communications relevant to financial crime investigations
  • Source of funds documentation
  • Source of wealth documentation
  • Risk assessments
  • Other records required for legal or regulatory compliance
20

Account Restrictions and Enforcement

Where Acceliqs identifies potential financial crime risks or violations of this Policy, we may take appropriate action.

Such action may include:

Acceliqs may take action without prior notice where permitted or required by applicable law.

  • Requesting additional information
  • Restricting certain account features
  • Delaying transactions
  • Rejecting transactions
  • Suspending access
  • Freezing assets where legally permitted or required
  • Terminating an account or business relationship
  • Reporting suspicious activity
  • Cooperating with competent authorities
21

Employee and Internal Compliance Responsibilities

Employees, contractors, and representatives involved in relevant Acceliqs operations are expected to support the Company's financial crime prevention framework.

Responsibilities may include:

Acceliqs may provide appropriate AML and compliance training to relevant personnel.

  • Following applicable internal compliance procedures
  • Reporting suspicious activity internally
  • Maintaining confidentiality
  • Participating in compliance training where required
  • Cooperating with internal investigations
  • Avoiding activities that may expose Acceliqs to financial crime risks
22

Third-Party Service Providers

Acceliqs may work with third-party service providers to support various components of its technology and compliance infrastructure.

These may include providers of:

Acceliqs may conduct appropriate due diligence when selecting relevant third-party providers.

  • Identity verification services
  • Sanctions screening
  • Blockchain analytics
  • Fraud detection
  • Transaction monitoring
  • Payment processing
  • Other compliance-related technologies
23

Technology and Automated Monitoring

As a technology-focused ecosystem, Acceliqs may use automated systems to assist with compliance monitoring.

Such systems may help identify:

Automated monitoring does not necessarily replace human review.

Where appropriate, alerts or high-risk activities may be subject to additional investigation.

  • Unusual transaction patterns
  • Duplicate accounts
  • Suspicious behavioral activity
  • Geographic inconsistencies
  • High-risk transactions
  • Potential fraud indicators
  • Other compliance-related risks
24

AI and Financial Crime Prevention

Acceliqs recognizes the potential role of advanced technology and artificial intelligence in improving risk detection and operational monitoring.

Where appropriate, technology may be used to support the identification of:

However, automated technologies may be supplemented by human oversight and compliance review where appropriate.

The use of technology does not eliminate the need for compliance controls, governance, and responsible decision-making.

  • Unusual behavioral patterns
  • Transaction anomalies
  • Emerging risk indicators
  • Fraud patterns
  • Other potentially suspicious activities
25

User Responsibilities

Users of Acceliqs products and services agree to provide accurate and truthful information where requested.

Users must not:

Users may be required to update information where it becomes inaccurate or outdated.

  • Provide false identification information
  • Impersonate another person
  • Conceal beneficial ownership
  • Use the platform to process criminal proceeds
  • Attempt to evade compliance procedures
  • Circumvent geographic restrictions
  • Attempt to manipulate verification processes
  • Engage in any unlawful financial activity
26

Changes to This Policy

Acceliqs may update this AML Policy from time to time to reflect:

Where material changes are made, the updated version may be published through the Acceliqs website or other appropriate communication channels.

Users are encouraged to review this Policy periodically.

  • Changes in applicable laws
  • Regulatory developments
  • New products or services
  • Emerging financial crime risks
  • Technological developments
  • Improvements to internal compliance procedures
27

Limitation of Services

The existence of this AML Policy does not guarantee that every product or service offered within the Acceliqs ecosystem will be available in every jurisdiction.

Certain products may be subject to:

Access to future products, including exchange services, digital asset products, staking mechanisms, or other ecosystem features, may be subject to additional policies and requirements.

  • Regulatory approvals
  • Licensing requirements
  • Geographic limitations
  • Product-specific terms
  • Eligibility requirements
  • Additional compliance procedures
28

Compliance Contact

Questions regarding this Anti-Money Laundering Policy or compliance-related matters may be directed to:

Acceliqs Compliance TeamEmail: [Insert Compliance Email Address]
29

Important Notice

This AML Policy provides a general overview of Acceliqs' approach to preventing money laundering, terrorist financing, fraud, sanctions violations, and other forms of financial crime.

The specific procedures applied to a user, transaction, product, or service may vary depending on applicable legal requirements, jurisdiction, risk assessment, and the nature of the service.

Acceliqs reserves the right to take any action reasonably necessary to comply with applicable laws, regulations, regulatory guidance, sanctions requirements, and financial crime prevention obligations.

30

Acknowledgement

By accessing or using Acceliqs products or services, users acknowledge that they may be required to comply with applicable identity verification, transaction monitoring, sanctions screening, and financial crime prevention procedures.

Failure to cooperate with reasonable compliance requests may result in restrictions, suspension, or termination of access to certain Acceliqs products or services.

Acceliqs is committed to building a responsible ecosystem where innovation, intelligent technology, and compliance can evolve together.

Our compliance framework may evolve alongside our products, technologies, regulatory obligations, and the broader financial technology environment.

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