Anti-Money Laundering Statement

1. Why we have this policy

Fast, cross-border payment services are a target for criminals who launder money, fund terrorism, get around sanctions, commit fraud or manipulate markets. Fundorra runs a compliance programme to keep that activity off the platform, catch it when someone tries, and report it when the law requires. This statement summarises the programme; it applies to all accounts and all employees.

2. Matching checks to risk

Not every customer carries the same risk, so not every customer receives the same checks. We look at who the customer is, which countries are involved, which products they use, and how much and how often they transact, then decide the level of monitoring from there. Higher-risk customers face more thorough checks and more frequent reviews.

3. Identity checks (KYC)

Before we pay any withdrawal, and before trading goes above set limits, we verify each account holder. As part of this we collect or check:

• Basic personal details: legal name, birth date, citizenship and where you live.
• An official photo ID, tested for authenticity, plus a liveness check when required.
• Whether you appear on sanctions lists, in politically exposed person databases or in negative news coverage.
• For businesses, a map of ownership and control that ends with the real people who ultimately benefit.

We will not accept anonymous accounts, fake names, or accounts run on behalf of someone who is not disclosed to us. If a customer will not give us the information we need, the account is not opened, or is closed.

4. Enhanced due diligence

Some situations call for more checks: a link between the customer or a counterparty and a high-risk country; a customer who is, or is close to, a politically exposed person; money whose origin is unclear; or account activity that doesn't match what we know about the customer. Here we must see evidence of where the funds and the customer's wealth come from before we continue.

5. Sanctions screening

Every customer and counterparty is checked against the relevant sanctions lists on joining, and the checks continue for as long as the relationship lasts. We do not deal with sanctioned people or organisations, and we block any transaction our screening flags.

6. Transaction monitoring

Our systems watch activity automatically, and our compliance team reviews the alerts. Patterns we look out for include:

• Funds that come in and go straight back out without meaningful trading.
• Payments broken into amounts just under a reporting or verification limit.
• Transfers linked to coin mixers, darknet marketplaces, ransomware groups or sanctioned parties, in either direction.
• One device, IP address, payment method or wallet turning up across several accounts.
• Trades that seem coordinated between accounts, or that appear built to move money from one account to another by losing on purpose.
• Activity that doesn't make sense for the customer's declared job, income or reasons for using Fundorra.

Blockchain analysis tools also show us where crypto deposits originate and where withdrawals are sent.

7. Reporting to the authorities

If an internal investigation leaves a suspicion unresolved, we file a report with the appropriate authority. The customer is not told about the report, because tipping someone off is a criminal offence in most countries. We cooperate with lawful requests from regulators and police, and funds may be frozen or an account suspended if we are instructed to, or if that is needed to stop a crime.

8. Record retention

Identity documents, transaction records, screening results and investigation files stay on file for at least five years after a customer relationship ends (longer if the law requires), and we provide them to authorities when lawfully asked.

9. Responsibility and staff training

Oversight sits with a named compliance officer, who in turn is accountable to the senior leadership team. Staff learn their obligations when they join and receive refresher training regularly; every employee has to raise any suspicion internally. A review takes place every twelve months at minimum, plus any time a major product or legal change occurs.

10. Your obligations

Keep the information you give us accurate and current, and use only money that is legally yours. Your account is for you alone — never lend it out or allow others to channel funds through it. If an account is used like this, we will close it, and the money involved may be frozen and reported.