AML/CTF and sanctions statement

The AIFC AML, CTF and Sanctions Rules and AFSA guidance; the Law of the Republic of Kazakhstan No. 191-IV "On Counteracting Legalisation (Laundering) of Proceeds of Crime and Financing of Terrorism" to the extent it applies in the AIFC; and FATF Recommendations as reflected in the AIFC framework.

The Board of Directors is ultimately responsible for the AML/CTF framework and approves this Policy at least annually. An independent Compliance Officer and a Money Laundering Reporting Officer (MLRO) with direct access to the Board oversee the framework, assess suspicions and report to the authorities. Controls follow the three-lines-of-defence model and are subject to periodic independent review.

Before any relationship or transaction we identify and verify every client, beneficial owner (25% or more, or other control) and authorised representative using reliable, independent sources, including electronic identity verification with liveness checks for non-face-to-face onboarding. We establish the purpose of the relationship and the expected source of funds, and every client receives a risk rating that drives the depth of ongoing monitoring.

We do not onboard clients who refuse to provide identification or beneficial ownership information, who are subject to sanctions, or who are known or suspected to be involved in criminal activity.

High-risk clients, including politically exposed persons and clients linked to higher-risk jurisdictions or opaque structures, require senior management approval, documented source of funds and source of wealth, and more frequent reviews.

Every incoming digital asset transfer is screened with blockchain analytics before it is credited. Exposure to sanctioned addresses, darknet markets, ransomware, fraud or mixing services leads to blocking, a request for information or escalation to the MLRO. We comply with the Travel Rule under the AIFC AML Rules: for transfers to or from other service providers we exchange originator and beneficiary information, carry out counterparty due diligence, and do not execute transfers where required information is missing. Transfers involving self-hosted wallets are subject to ownership verification and risk-based measures.

Clients, beneficial owners, counterparties and wallet addresses are screened against UN Security Council lists, Republic of Kazakhstan lists and, where relevant, EU, UK and US sanctions regimes — at onboarding and continuously as lists change. Confirmed matches lead to refusal or termination of the relationship, freezing of assets where required, and reporting to the competent authorities.

Unusual activity is reviewed and, where suspicion cannot be dispelled, escalated to the MLRO, who decides on filing a suspicious transaction report with the Financial Monitoring Agency of the Republic of Kazakhstan and notifying AFSA. Tipping off a client about a report is prohibited.

Due diligence records, transaction records and reports are kept for at least six years. All staff complete AML/CTF and sanctions training at induction and at least annually.

Clients must provide accurate information, notify us of changes, and supply source of funds or source of wealth evidence on request. We may restrict, suspend or close accounts where due diligence cannot be completed.