Anti-Money Laundering Policy

Ntradex Solutions LTD ("Ntradex," "we," "our," or "us") is a company registered in England and Wales, with its registered office in London, England. We are authorised and regulated by the Financial Conduct Authority (FCA) and comply with the Money Laundering Regulations 2017 (MLR 2017) and the Payment Services Regulations 2017.

This AML Policy has been prepared in accordance with the Proceeds of Crime Act 2002 (POCA) and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017). It applies to all Ntradex products, services, and platforms, and to all individuals and businesses that use our services, regardless of where they are located.

Ntradex has zero tolerance for money laundering, terrorist financing, and any other form of financial crime. We are committed to protecting the integrity of the global financial system and cooperating fully with law enforcement and regulatory authorities.

Money laundering is the process by which the proceeds of criminal activity are made to appear legitimate. It typically involves three stages: placement (introducing illicit funds into the financial system), layering (obscuring the trail through complex transactions), and integration (reintroducing the funds into the economy in a form that appears legitimate).

Terrorist financing refers to the provision of funds — whether from legitimate or illegitimate sources — to individuals or groups for the purpose of carrying out terrorist acts, or to support terrorist organisations. Unlike money laundering, the funds involved in terrorist financing may originate from entirely legal sources.

Both offences are serious crimes under UK law, including under POCA 2002, the Terrorism Act 2000 (as amended by the Anti-terrorism, Crime and Security Act 2001 and the Terrorism Act 2006), and the Counter-Terrorism and Security Act 2015. Individuals and organisations found guilty of either offence face severe criminal penalties, including imprisonment and asset forfeiture.

Ntradex's AML compliance programme is anchored in UK law and guided by international standards. Our primary obligations arise under:

Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR 2017) — The UK's principal AML/CFT secondary legislation. As an FCA-authorised payment institution, Ntradex is a "relevant person" under the MLR 2017 and is required to maintain a compliance programme, conduct customer due diligence, keep records, and report certain matters to the National Crime Agency (NCA).

Proceeds of Crime Act 2002 (POCA) — POCA creates the principal money laundering offences in the UK, including arrangements, acquisition, use, and possession of criminal property. POCA also requires authorised disclosure (Suspicious Activity Reports) to the NCA where a person knows or suspects that another person is engaged in money laundering.

FCA Rules and Guidance — The Financial Conduct Authority supervises Ntradex Solutions LTD's compliance with the MLR 2017 and publishes guidance that informs our policies, procedures, and risk assessments.

Financial Action Task Force (FATF) — As an international standard-setter for AML/CFT, FATF recommendations and country-risk assessments inform how we assess the risk profiles of transactions, corridors, and counterparties. Ntradex treats jurisdictions on the FATF grey list or black list as high-risk by default, applying enhanced due diligence to transactions involving those countries.

Customer identity verification is the cornerstone of our AML programme. We are required by law to verify the identity of every customer before providing services, and to maintain records of that verification. Our KYC procedures are designed to ensure that we know who our customers are, understand the nature of their business, and can assess the risk they represent.

4.1 Identity Verification

All personal account holders must provide government-issued photo identification before transacting. Business account holders must provide corporate documentation including certificates of incorporation, beneficial ownership registers, and identity verification for all individuals who own 25% or more of the business.

We use a combination of document verification, biometric checks, and third-party identity verification services to confirm that the information provided matches the individual presenting it. We reserve the right to request additional documentation at any time.

4.2 Beneficial Ownership

For business accounts, Ntradex identifies and verifies the beneficial owners of the entity — those individuals who ultimately own or control the business. We are required under the MLR 2017 to collect and maintain beneficial ownership information and to update it when it changes.

4.3 Politically Exposed Persons (PEPs) and Heads of International Organisations (HIOs)

Ntradex screens all customers against PEP and HIO lists as part of onboarding and on an ongoing basis. A Politically Exposed Person is an individual who holds or has held a prominent public function domestically or internationally, or is a close associate or family member of such a person. Given the elevated risk of corruption associated with PEPs, we apply enhanced due diligence measures to all PEP relationships, including senior management approval, additional source-of-funds verification, and more frequent transaction monitoring.

4.4 Customer Risk Assessment

Each customer is assigned a risk rating — low, medium, or high — based on a combination of factors including the nature of their business, the countries and corridors they transact in, their transaction volumes and patterns, and the results of screening against sanctions lists and adverse media. Higher-risk customers are subject to more intensive monitoring and periodic review.

Examples of customer types that may attract elevated risk include: businesses that deal primarily in cash or cash equivalents; companies operating in sectors with historically high exposure to illicit finance (such as armaments, unregulated charities, and high-value goods dealers); and customers whose transactions are inconsistent with their stated business purpose.

4.5 Sanctions Screening

Ntradex screens all customers and transactions against applicable sanctions lists, including those maintained by the Government of Canada (the Special Economic Measures Act and United Nations Act lists), the U.S. Office of Foreign Assets Control (OFAC), the UK Office of Financial Sanctions Implementation (OFSI), and the European Union. Any customer or transaction that matches a sanctions designation will be blocked, and Ntradex may be required to report such a match to the relevant authority.

Ntradex employs automated and manual transaction monitoring systems to detect activity that may be indicative of money laundering, terrorist financing, or other financial crime. Our monitoring systems apply risk-based rules and behavioural analytics to flag transactions that are unusual, inconsistent with a customer's profile, or consistent with known patterns of illicit activity.

Indicators of suspicious activity include, but are not limited to: transactions with no apparent economic purpose; structuring transactions to avoid reporting thresholds; use of multiple accounts or third-party payers to obscure the origin or destination of funds; sudden significant changes in transaction volume; and requests to send funds to or receive funds from high-risk jurisdictions without a clear business rationale.

Ntradex also monitors for indicators of fraud, sanctions evasion, and proliferation financing as part of its broader financial crime risk management framework.

As an FCA-authorised payment institution, Ntradex is legally required to make disclosures to the National Crime Agency (NCA) under POCA 2002 and the Terrorism Act 2000. These obligations are not discretionary, and failure to comply is a criminal offence. Our primary reporting obligations are as follows:

6.1 Suspicious Activity Reports (SARs)

Ntradex must submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) via the UKFIU when there are reasonable grounds to know or suspect that a person is engaged in, or attempting, money laundering or terrorist financing. The obligation to file a SAR arises from knowledge or suspicion — it does not require certainty, nor does it require that the transaction be completed. SARs should be submitted promptly; in cases involving a request for a Defence Against Money Laundering (DAML), the NCA must respond within 7 working days.

6.2 High Value and Cash Transaction Monitoring

Ntradex monitors and records all cash transactions and applies enhanced scrutiny to high-value transactions as part of its transaction monitoring programme. Where cash transactions or structured transactions raise suspicion of money laundering or tax evasion, we will file a SAR with the NCA. There is no fixed threshold for cash reporting in the UK; the obligation to report arises from suspicion rather than a specific monetary amount.

6.3 Transfer of Funds Compliance

Ntradex complies with the Transfer of Funds (Information on the Payer) Regulations 2017, which require that complete payer and payee information accompany electronic fund transfers. Where information is missing or incomplete, Ntradex may be required to reject or hold the transfer and to file a SAR if the circumstances raise suspicion.

6.4 Terrorist Financing Disclosures

If Ntradex knows or has reasonable cause to suspect that it is in possession or control of property that belongs to a terrorist group or that has been used or will be used to facilitate a terrorist activity, it must immediately disclose this to the NCA under the Terrorism Act 2000. Ntradex will also notify HM Treasury's Office of Financial Sanctions Implementation (OFSI) in connection with any relevant financial sanctions obligations.

The MLR 2017 requires Ntradex to keep records of all transactions, customer identification documents, beneficial ownership information, and related correspondence for a minimum of five (5) years from the end of the business relationship or the date of the transaction. Records must be kept in a form that can be produced to the FCA or NCA upon request, and must be accessible and legible throughout the retention period.

Ntradex maintains its records in secure, encrypted storage systems with access controls appropriate to the sensitivity of the information. Records subject to an FCA, NCA, or court production order will be produced in the required format and within the required timeframe.

Customers who close their accounts should note that Ntradex retains their identity, transaction, and account records for the full five-year retention period required by law, notwithstanding the closure of the account. This obligation takes precedence over any request for earlier deletion of personal data.

Ntradex reserves the absolute right to refuse to process any transaction, to suspend or terminate any account, or to decline to onboard any customer where:

We are unable to verify the identity of a customer or beneficial owner to our satisfaction; a customer provides false, misleading, or incomplete information; a transaction appears to be designed to circumvent legal reporting requirements; a customer or counterparty is the subject of a sanctions designation or a court order; or we have reasonable grounds to suspect that a transaction is connected to money laundering, terrorist financing, fraud, or any other financial crime.

Where Ntradex terminates a relationship or refuses a transaction on AML/ATF grounds, we may be required by law to file a SAR with the NCA. In such cases, and consistent with the tipping-off prohibition described in Section 6.4, Ntradex will not disclose the reason for the refusal or termination to the customer.

Any customer who provides false identification documents or knowingly makes false representations to Ntradex for the purpose of evading AML controls will be reported to law enforcement authorities and may be subject to criminal prosecution.

Not all jurisdictions present the same level of AML/ATF risk. Ntradex maintains a country risk matrix that is updated regularly to reflect current FATF guidance, Government of Canada advisories, and our own analysis of the corridors in which we operate.

Jurisdictions on the FATF grey list (subject to increased monitoring) or black list (high risk, subject to a call for action) are treated as high-risk by Ntradex. Transactions to or from these jurisdictions, or involving counterparty financial institutions based there, are subject to enhanced due diligence, including senior management approval for new relationships and more frequent review of existing ones.

Our primary operating corridors — including Nigeria, Ghana, Kenya, South Africa, Canada, Australia, the United Kingdom, and the United States — each carry their own risk profile, and our controls are calibrated accordingly. We continuously refine our corridor-specific monitoring rules to reflect the most current intelligence about financial crime patterns in those markets.

Ntradex's AML compliance programme is overseen by a designated Compliance Officer who is responsible for implementing and maintaining the programme, reporting to senior management on compliance matters, and serving as the primary point of contact with the FCA, the NCA, and other regulatory authorities.

The programme includes: written policies and procedures that reflect current regulatory requirements; ongoing employee training on AML/ATF obligations, red flags, and internal escalation procedures; an independent audit function that periodically tests the effectiveness of controls; and a risk assessment process that evaluates Ntradex's exposure to money laundering and terrorist financing and informs the calibration of controls.

All Ntradex employees, contractors, and agents who interact with customers or process transactions are required to complete AML/ATF training appropriate to their role, and to report any suspicious activity they observe through Ntradex's internal escalation process without delay. Retaliation against any employee who makes a good-faith report of suspected financial crime is strictly prohibited.

By using Ntradex's services, you agree that you will not use the platform for any purpose connected to money laundering, terrorist financing, fraud, sanctions evasion, or any other illegal activity. You agree to provide accurate and complete information during onboarding and throughout your relationship with Ntradex, and to promptly notify us of any material changes to your circumstances, business purpose, or ownership structure.

You acknowledge that Ntradex is required by law to collect, verify, and retain your identity information and transaction records, and that Ntradex may be required to report certain transactions and information about you to the NCA, the FCA, HMRC, and other government authorities without notifying you.

You also acknowledge that Ntradex may decline to process transactions or terminate your account without explanation in circumstances where doing so is required by law or is necessary to comply with our AML/ATF obligations, and that no liability attaches to Ntradex for such actions where they are taken in good faith.

Your acceptance of Ntradex's Terms and Conditions at the time of account creation constitutes your acknowledgement that you have read and understood this AML Policy and agree to be bound by its requirements.

Ntradex reviews and updates this AML Policy at least annually, or more frequently when required by changes in law, regulation, or the risk environment. Material changes will be published on our website and communicated to existing customers by email at least fourteen (14) days before they take effect.

The current version of this policy is always available at ntradex.co.uk/aml-policy. Your continued use of our services following the effective date of any update constitutes acceptance of the revised policy.