Anti-Money Laundering Policy

1. Purpose

Platforms that move value quickly and across borders attract money laundering, terrorist financing, sanctions evasion, fraud and market abuse. QuantVoro operates a programme designed to keep that activity off the platform, to detect it when it is attempted, and to report it where the law requires. This policy summarises that programme; it applies to every account and every member of staff.

2. Risk-based approach

Controls are applied in proportion to risk. We assess each relationship on the customer's profile, the countries involved, the products used, and the pattern and size of transactions, then set the level of scrutiny accordingly. Higher-risk relationships receive enhanced diligence and are reviewed more often.

3. Know Your Customer

We identify every account holder before releasing withdrawals and before trading passes defined thresholds. Verification includes:

• Legal name, date of birth, nationality and residential address.
• A government-issued identity document, checked for authenticity, with a liveness check where required.
• Screening against sanctions lists, and against politically-exposed-person and adverse-media sources.
• For corporate accounts, ownership and control structure down to the beneficial owners.

We do not accept anonymous accounts, accounts opened under a false name, or accounts operated for an undisclosed third party. Where a customer will not provide what we ask for, we decline or close the relationship.

4. Enhanced due diligence

Additional checks apply where the customer or a counterparty is connected to a high-risk jurisdiction, where the customer is a politically exposed person or a close associate of one, where the source of funds is unclear, or where activity does not fit the profile we hold. In those cases we require evidence of source of funds and source of wealth before proceeding.

5. Sanctions

We screen customers and counterparties against applicable sanctions regimes at onboarding and continuously thereafter. We do not open or maintain relationships with designated persons or entities, and we block transactions where screening requires it.

6. Transaction monitoring

Activity is monitored automatically and reviewed by staff. Patterns that draw scrutiny include:

• Deposits followed by withdrawal with little or no trading in between.
• Amounts structured to sit just under a reporting or verification threshold.
• Funds arriving from, or leaving to, addresses linked to mixers, darknet markets, ransomware or sanctioned entities.
• Multiple accounts sharing a device, IP address, payment instrument or wallet.
• Trading that appears coordinated between accounts, or designed to move value between them at a loss.
• Activity inconsistent with the customer's stated occupation, income or purpose.

We use blockchain-analytics tools to assess the provenance of on-chain deposits and the destination of withdrawals.

7. Reporting and cooperation

Where an internal review does not dispel a suspicion, we file a report with the competent authority. We do not tell the customer that a report has been made — doing so is a criminal offence in most jurisdictions. We respond to lawful requests from regulators and law enforcement, and we may freeze funds or suspend an account where we are directed to, or where it is necessary to prevent an offence.

8. Record keeping

Identity records, transaction records, screening results and investigation files are retained for at least five years after the end of the relationship, or longer where the law requires, and are made available to authorities on lawful request.

9. Governance and training

A designated compliance officer owns this programme and reports to senior management. Staff are trained on their obligations when they join and at regular intervals, and every member of staff is required to escalate suspicious activity internally. The programme is reviewed at least annually and after any material change in our products or in the law.

10. What we expect from you

Give us accurate information, keep it current, and use only funds that are lawfully yours. Never let anyone else use your account or route their funds through it. Accounts used that way are closed, and the funds involved may be frozen and reported.