Anti-Money Laundering Policy

We maintain a risk-based Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) program designed to comply with applicable law in the jurisdictions in which we operate and with the compliance requirements imposed on us contractually by our licensed banking and Banking-as-a-Service (BaaS) partners. This program applies to every SyncroFi account, individual or business, and every transaction processed through the platform.

Every individual customer must complete identity verification before a virtual account is provisioned or any funds may be received or paid out. This includes government-issued photo identification, biometric liveness verification, and, where applicable, proof of address, performed through a certified third-party identity verification vendor.

We verify the legal existence of the business against the relevant company registry and screen every identified UBO and director — not only the account’s authorized representative — against global sanctions and Politically Exposed Persons (PEP) databases before the corresponding virtual account is generated. No business virtual account is provisioned until all required parties clear this screening.

We screen all customers, authorized representatives, UBOs, and directors against applicable global sanctions lists and PEP databases at onboarding, on an ongoing periodic basis, and again for every payout beneficiary at the time a withdrawal is requested. A payout will not be released if the named beneficiary triggers a sanctions or high-severity PEP match.

Every transaction is screened by automated, rules-based monitoring designed to detect activity inconsistent with a customer’s stated profile, including unusual transaction velocity, structuring patterns, and rapid movement of funds. New accounts are subject to lower velocity limits that step up only after a period of clean transaction history, and any flagged activity is escalated for manual compliance review before an associated payout is released.

Where our review identifies activity reasonably suspected of relating to money laundering, terrorist financing, fraud, or sanctions evasion, we escalate internally to our designated compliance officer and, where warranted, file a report with the relevant Financial Intelligence Unit, in accordance with applicable law. Consistent with legal requirements around such filings, we are not able to confirm or deny whether a report has been made about a particular account.

You agree to provide accurate information during onboarding and to promptly update us of any change, including a change in a business’s beneficial ownership structure. We may request additional information or documentation at any time to satisfy our ongoing due diligence obligations, and may suspend or restrict an account where requested information is not provided.

This program is overseen by Softsyncron Limited’s designated compliance officer and is subject to periodic internal review and independent audit. This public summary may be updated from time to time; it does not limit or replace the more detailed compliance controls described in our internal AML/KYC program documentation, which is available to our regulators and banking/BaaS partners on request.