Anti-Money Laundering Policy

Ntradex, Inc. ("Ntradex," "we," "our," or "us") is a corporation incorporated in the State of Delaware, registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury. We hold state money transmitter licences in each state where required and are registered with the Nationwide Multistate Licensing System (NMLS) where applicable.

This AML Policy has been prepared in accordance with the Bank Secrecy Act (BSA), the USA PATRIOT Act, and applicable FinCEN regulations and guidance. 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 U.S. federal law, including under 18 U.S.C. §§ 1956–1957 (money laundering statutes), the Bank Secrecy Act, and 18 U.S.C. § 2339B and related statutes governing material support for terrorism. 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 U.S. federal and state law and guided by international standards. Our primary obligations arise under:

Bank Secrecy Act (BSA) / 31 C.F.R. Chapter X — The BSA is the United States' principal AML statute. As a FinCEN-registered MSB, Ntradex is required to maintain a written AML programme, conduct customer due diligence (CDD) and beneficial ownership identification, keep records, and report certain transactions to FinCEN.

USA PATRIOT Act (31 U.S.C. § 5318) — The PATRIOT Act strengthened BSA requirements by mandating robust Customer Identification Programmes (CIP), enhanced due diligence for certain foreign accounts, and information-sharing with law enforcement and other financial institutions under Section 314(b) of the BSA.

FinCEN Regulations and Guidance — FinCEN publishes rules, advisories, and geographic targeting orders (GTOs) that inform our policies, procedures, and risk assessments. We monitor FinCEN updates and adjust our controls accordingly.

State Money Transmitter Laws — Ntradex holds and maintains state money transmitter licences as required. State regulators may conduct examinations and issue directives that complement our federal AML obligations.

OFAC Sanctions Programme — The U.S. Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions. Ntradex screens all customers and transactions against OFAC's Specially Designated Nationals (SDN) list and other applicable sanctions lists.

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 BSA and FinCEN CDD Rule (31 C.F.R. § 1010.230) 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 a FinCEN-registered MSB, Ntradex is legally required to file certain reports with FinCEN. These reports are not discretionary — they are obligations under the BSA, and failure to file them is a federal crime. Our primary reporting obligations are as follows:

6.1 Suspicious Activity Reports (SARs)

Ntradex must file a Suspicious Activity Report (SAR) with FinCEN when it knows, suspects, or has reason to suspect that a transaction involves funds derived from illegal activity, is designed to evade BSA reporting requirements, lacks a lawful purpose, or involves the use of the MSB to facilitate criminal activity. SARs involving ongoing suspicious activity must be filed within 30 days; where no subject is identified, the filing deadline is 60 days. SARs are filed electronically through FinCEN's BSA E-Filing System.

6.2 Currency Transaction Reports (CTRs)

Ntradex must file a Currency Transaction Report (CTR) with FinCEN for each currency transaction exceeding $10,000 USD (or its equivalent in another currency) conducted in a single business day by or on behalf of the same person. CTRs must be filed within 15 calendar days of the transaction date. Structuring transactions to avoid the CTR threshold is itself a federal crime under 31 U.S.C. § 5324.

6.3 Funds Transfer Recordkeeping (Travel Rule)

Under the BSA Travel Rule (31 C.F.R. § 1010.410), Ntradex is required to pass along certain information — including the name, address, and account number of the originator and beneficiary — in connection with funds transfers of $3,000 or more. Ntradex maintains records of all covered transfers and produces them to FinCEN or law enforcement upon lawful request.

6.4 OFAC Sanctions Blocking and Reporting

If Ntradex identifies that a transaction involves a Specially Designated National (SDN), blocked country, or other sanctioned party, it must immediately block the transaction, decline to process it, and report the blocked property to OFAC within 10 business days. Ntradex notifies FinCEN and relevant law enforcement as required by applicable sanctions orders.

The BSA 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 date the record was created. Records must be kept in a form that can be produced to FinCEN, the IRS, or other competent authorities upon lawful 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 a FinCEN, IRS, or court production order or law enforcement request 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 FinCEN. In such cases, and consistent with the SAR confidentiality requirements 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 FinCEN, OFAC, 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 FinCEN, OFAC, the IRS, 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.com/aml-policy. Your continued use of our services following the effective date of any update constitutes acceptance of the revised policy.