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AML POLICY & KYC REQUIREMENTS

1. Policy Statement of InterTrust – Corporate Solutions (Nevis) Limited
InterTrust – Corporate Solutions (Nevis) Limited is committed to preventing and actively combating money laundering and the financing of terrorism or other criminal activities. We strictly comply with all applicable anti-money laundering (AML) and counter-financing of terrorism (CFT) regulations and requirements.
Money laundering involves activities intended to disguise the origins of illicitly obtained funds, making them appear as though they originate from legitimate sources. This process typically occurs in three stages:

• Placement: Illegally obtained funds are introduced into the financial system, for instance, via cash deposits or purchasing monetary instruments.
• Layering: Funds are transferred across multiple accounts or institutions to obscure their origin.
• Integration: The funds re-enter the economy, often through the purchase of legitimate assets or businesses.

Terrorist financing may not necessarily involve illicit proceeds; it often focuses on concealing the origin or intended use of funds, which may include legitimate sources such as charitable donations, personal income, or government sponsorship. While the motivations differ, methods used for terrorist financing can closely resemble traditional money laundering techniques. Importantly, terrorist activities may require only modest sums and simple transactions.
Our AML/CFT policies, procedures, and internal controls are designed to ensure full regulatory compliance and are subject to ongoing review and updates to reflect changes in laws and business operations.

2. AML/CFT Compliance Officer Designation and Responsibilities
InterTrust – Corporate Solutions (Nevis) Limited has appointed a Chief Compliance Officer (CCO) responsible for overseeing our AML/CFT compliance program. The CCO’s duties include:

• Monitoring ongoing compliance with AML/CFT obligations.
• Coordinating employee training and communication.
• Ensuring software and system configurations meet compliance requirements.
• Maintaining all AML/CFT-related records.
• Reviewing and filing Suspicious Transaction Reports (STRs) with the Financial Services Authority (FSA) as necessary.

The CCO has full authority to enforce the AML/CFT program. Contact details for the CCO, including name, title, mailing address, email, and phone number, will be made available to relevant stakeholders and updated promptly upon any changes. An annual review of this information will be conducted and completed within 30 business days following the end of each calendar year.

3. Customer Due Diligence (CDD) Levels
4.1. Level 1 Clearance
Customers must submit full contact details before being allowed to deposit, trade, or withdraw. This level permits up to USD 100 daily and USD 1,000 monthly in transactions.
4.2. Level 2 Clearance
Permits up to USD 1,000 daily and USD 10,000 monthly. Customers must submit scanned photographic identification and proof of address, as outlined in Section 5.
4.3. Level 3 Clearance
Allows for unlimited transactions. Original certified copies of photographic ID and proof of address are required and must be physically received by the company.

4. Customer Identification and Know Your Client (KYC) Procedures
We gather sufficient information to identify each customer and apply risk-based verification measures. All CDD and verification procedures, results, and discrepancies will be recorded.
Required Information for Account Activation (FIAT only):

• Full name
• Date and place of birth (for individuals)
• Nationality, gender, email, and phone number
• Proof of address or principal place of business
• Government-issued photo identification

Refusal to Provide Information
If a customer refuses to provide required information or provides false or misleading data, the account will be deactivated and reviewed for possible closure. The CCO will determine if reporting to authorities is warranted.

Verification Methods
We employ both documentary and non-documentary methods (e.g., email/phone validation). Acceptable documents include:

• Individuals: Passport, driver’s license, or national ID; recent utility bill or bank statement (under 3 months old).
• Corporations: Certificate of incorporation, articles of association, beneficial owner identification, and documents for at least two directors.

For Level 3, certified documents must be signed and verified by a qualified professional, including translations where applicable. Obvious document forgeries will be flagged for review.

When Verification Fails
If we cannot reasonably verify a customer’s identity, the account will remain deactivated or be closed, and the matter may be reported to the FSA or relevant authority.
Recordkeeping
All records related to identity verification, document types, methods used, and resolutions will be retained for five years after the account is closed or the verification was completed.

Government Watchlist Comparison
When official terrorist watchlists are issued for CDD purposes, we will screen all new customers and act in accordance with applicable directives.

Customer Notification
Customers will be informed via email and the platform interface that we are required to collect identifying information to comply with AML/CFT laws:

Important: To help combat terrorism financing and money laundering, we are required to collect and verify personal information. When activating an account for FIAT currency transactions, we will request your name, address, date of birth, and official identification documents.

5. Enhanced Customer Due Diligence (EDD)
To detect and report suspicious activity, we assess the risk profile of each customer. For high-risk accounts—including offshore corporations, individuals from high-risk jurisdictions, or customers with questionable documents—we implement enhanced due diligence, including:

• Verification of beneficial owners
• Financial institution references
• Proof of source of funds

6. Politically Exposed Persons (PEPs)
InterTrust – Corporate Solutions (Nevis) Limited does not open or maintain accounts for politically exposed persons (PEPs), due to the increased AML/CFT risk such individuals present.

7. Monitoring Accounts for Suspicious Activity
InterTrust – Corporate Solutions (Nevis) Limited continuously reviews account activity for unusual transaction size, volume, patterns, or types, taking into account relevant risk factors and the red flags listed in § 8 (b). The Chief Compliance Officer (CCO)—or a designated delegate—oversees this monitoring, documents the process, determines any follow up actions, and, where warranted, reports concerns to the proper authorities only after an appropriate internal investigation that may include external data sources.

a) Emergency Notification
If we detect activity requiring immediate attention—such as suspected terrorist financing or an active money laundering scheme—we will contact the appropriate law enforcement agency by telephone without delay.

b) Red Flags
Indicators of potential money laundering or terrorist financing include, but are not limited to, the following:

Customer information

• Presents identification documents that are unusual, suspicious, or cannot be readily verified.
• Appears unwilling to provide full details about business purpose, ownership, anticipated activity, or location.
• Refuses to identify a legitimate source of funds, or supplies information that is false, misleading, or clearly inconsistent with known facts.
• Exhibits a background that conflicts with the stated business profile.
• Lacks a discernible reason for using our services.

Evasion attempts

• Reluctant to furnish data needed for regulatory reports or abandons a transaction when asked.
• Attempts to dissuade staff from filing required reports or maintaining records.
• Structures deposits, withdrawals, or purchases to remain below reporting thresholds.
• Shows unusual concern about our reporting obligations or AML/CFT policies.

Funds transfer anomalies

• Sends or receives wires involving secrecy jurisdictions or high risk territories with no apparent business rationale.
• Receives numerous small wires or deposits (e.g., checks, money orders) that are quickly withdrawn or wired elsewhere, inconsistent with history—potentially indicative of a Ponzi scheme.
• Conducts repetitive, unusually large, or patternless wire transfers lacking a clear purpose.

Activity inconsistent with stated business

• Sudden, unexplained changes in transaction patterns.
• Transfers or journal entries between accounts with no obvious commercial justification.
• Maintains multiple personal or shell entity accounts without apparent need.
• Acts for an undisclosed principal yet withholds requested information.

Other warning signs

• Sustains high account activity with minimal investment trades.
• Deposits funds for a long term position, then rapidly liquidates and withdraws proceeds.
• Receives direct inquiries from law enforcement.

c) Responding to Red Flags
Any employee who observes a red flag must immediately notify the CCO. Guided by the CCO, the firm will decide whether to collect more information (internally or via third party sources), contact regulators, freeze the account, and/or file a report.

8. Suspicious Transaction Reporting
a) Regulatory Reports
We will submit a report to the Financial Services Authority (FSA) or other competent regulator for any transaction—or series of related transactions—of USD 10,000 or more where we know, suspect, or have reason to suspect that:

1. the funds derive from illegal activity or the transaction is intended to conceal such origin;
2. the transaction is structured to evade regulatory requirements;
3. the transaction lacks an apparent lawful purpose given the customer’s profile, and no reasonable explanation exists after review; or
4. InterTrust Corporate Solutions (Nevis) Limited is being used to facilitate criminal conduct.

Urgent matters (e.g., terrorist financing) will also be reported immediately to law enforcement. We may voluntarily report any other suspicious activity we deem relevant. Summaries of all reports are provided periodically to the Board of Directors and senior management.

b) Currency Transaction Reports
FIAT transfers exceeding USD 10,000—once an account is activated—may be reported to the authorities in accordance with applicable rules.

c) Currency Transportation
InterTrust – Corporate Solutions (Nevis) Limited does not accept currency or monetary instruments delivered, mailed, or shipped directly to us. All cash movements must pass through regulated financial institutions or internationally recognized payment platforms.

9. AML/CFT Recordkeeping

a) Record Maintenance Responsibility
The CCO (or delegate) ensures that all AML/CFT records—customer identification, verification data, and funds transfer details—are properly created and stored for a minimum of five years.

b) Confidentiality of Reports
All reports and supporting documents are confidential, segregated from other corporate records, and disclosed only to authorized regulators or law enforcement agencies. The CCO handles all information requests.

10. Clearing and Introducing Relationships
We collaborate closely with counterpart institutions to detect and deter money laundering, sharing relevant data and documentation as required by AML/CFT legislation.

11. Training Programs
Under the CCO’s supervision, employees receive AML/CFT training at least annually, adjusted for company size, customer base, and legal developments. Training covers:

1. identifying red flags and potential money laundering or terrorist financing indicators;
2. escalation procedures and reporting timelines;
3. each employee’s compliance responsibilities;
4. record retention policies; and
5. disciplinary and legal consequences for non compliance.

We maintain records detailing participants, dates, and content, and provide specialized instruction for high risk roles as needed.

12. Independent Testing of the AML/CFT Program
An independent tester—neither the CCO nor anyone reporting to the CCO—will review the AML/CFT program at least once per calendar year, or more frequently if circumstances warrant. Findings are reported to the CCO, and all recommendations are addressed promptly and documented.

13. Confidential Reporting of Non Compliance
Employees must promptly report any suspected AML/CFT violations to the CCO; if the CCO is implicated, reports should be made to the independent testing officer. All reports are confidential, and whistle blowers are protected from retaliation.

14. Additional Risk Areas
InterTrust – Corporate Solutions (Nevis) Limited continually assesses emerging risks not covered above – such as regulatory changes or cybersecurity threats. Mitigation measures include maintaining regular contact with the FSA and conducting daily security checks on company servers, led by a dedicated security specialist.