Anti-Money Laundering (AML) Policy

Last updated: January 2025

1. Commitment

Erxtopay is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance. We maintain robust policies and procedures to detect, prevent, and report suspected money laundering and terrorist financing activities.

2. Know Your Customer (KYC)

All users must complete identity verification before using our transfer services:

• Basic verification: full name, email, phone number, and country of residence.
• Enhanced verification: government-issued photo ID, proof of address, and selfie for higher transfer limits.
• Ongoing due diligence: periodic re-verification and enhanced due diligence for high-volume users.

3. Transaction Monitoring

We monitor all transactions for suspicious activity, including:

• Unusual transaction patterns or volumes.
• Transfers involving sanctioned countries, entities, or individuals.
• Structuring activity (splitting transactions to avoid thresholds).
• Rapid movement of funds with no clear economic purpose.

4. Sanctions Screening

We screen all users and transactions against international sanctions lists including OFAC, EU sanctions, UN consolidated list, and relevant local sanctions. Matches result in immediate account suspension pending investigation.

5. Suspicious Activity Reporting

Where required by law, we file Suspicious Activity Reports (SARs) with the appropriate Financial Intelligence Unit (FIU). Employees are trained to identify and escalate red flags.

6. Record Keeping

We retain all customer identification records, transaction records, and compliance documentation for a minimum of 5 years (or longer where required by law) from the date of the transaction or account closure.

7. Risk-Based Approach

We apply a risk-based approach to AML/CTF compliance, with enhanced due diligence for:

• Politically Exposed Persons (PEPs).
• High-risk corridors or jurisdictions.
• High-value or unusual transactions.
• Customers with complex or opaque ownership structures.

8. Employee Training

All employees receive regular AML/CTF training covering their obligations, red flag indicators, and internal escalation procedures.

9. Blockchain Compliance

As a platform that uses blockchain rails for settlement, we also:

• Screen on-chain wallet addresses against known illicit addresses.
• Monitor for interaction with mixing services or known high-risk protocols.
• Maintain records of on-chain transaction hashes for audit trails.

10. Contact

For compliance-related enquiries, contact our compliance team at compliance@erxtopay.com.