AML/KYC Policy

This AML/KYC Policy applies exclusively to the AEXI Stablecoin Exchange service (USDT/USDC exchanges). Cross-chain token swaps and bridge operations facilitated through AEXI are not covered by this policy. AEXI acts solely as an aggregator of decentralized exchanges (DEXs), bridges, and liquidity providers. All swap and bridge transactions are executed directly through the selected third-party protocol. AEXI does not custody, hold, or control any funds during swap or bridge operations. If a blockchain transaction is flagged by third-party services (such as centralized exchanges) and a user subsequently encounters issues with their internal AML metrics, AEXI bears no responsibility. Users are advised to verify the AML status of their wallets and transactions independently before using any service.

AEXI operates as a global non-custodial platform. All AML/KYC procedures are designed in accordance with applicable international standards and local regulatory requirements.

Money laundering is defined as: 1. The conversion or transfer of property derived from criminal activity, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising the illicit origin of the property; 2. The acquisition, possession or use of property derived from criminal activity, knowing, at the time of receipt, that such property was derived from criminal activity; 3. The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property derived from criminal activity. Terrorist financing is defined as the financing and supporting of an act of terrorism and commissioning thereof as well as the financing and supporting of travel for the purpose of terrorism. Both international and local laws require AEXI to implement effective internal procedures to prevent money laundering, terrorist financing, and any form of suspicious activity.

AEXI has appointed a Money Laundering Reporting Officer (MLRO) responsible for the development and enforcement of AML/KYC procedures. The Compliance Officer is responsible for: • Establishing and updating internal policies and procedures for AML/CFT compliance; • Supervising all aspects of AEXI's anti-money laundering and counter-terrorist financing measures; • Collecting and analyzing information relating to unusual or suspicious transactions; • Reporting to the appropriate authorities in the event of suspicion of money laundering or terrorist financing; • Organizing training of employees on AML/CFT procedures; • Performing other duties and obligations related to compliance with applicable laws and regulations. The Compliance Officer is entitled to interact with law enforcement and regulatory authorities involved in the prevention of money laundering, terrorist financing, and other illegal activity.

AEXI utilizes amlbot.com as its official AML screening partner for all Stablecoin Exchange operations. Amlbot.com provides blockchain analytics and wallet risk assessment services. All users are required to conduct an independent AML check through amlbot.com before initiating a Stablecoin Exchange transaction.

The user must conduct an AML check through amlbot.com no later than three (3) minutes before making a payment on the exchange request. Each AML check is performed individually for every transaction, even if the same wallet address is used repeatedly. The user acknowledges that the AML status of their wallet or transaction may change at any time, including during the payment process. The user will receive a full AML report generated by amlbot.com. AEXI does not modify or filter the results provided by the screening partner. By proceeding with a Stablecoin Exchange transaction, the user confirms that they have reviewed the AML report and accept the associated risk.

The general AML risk threshold for accepting a transaction is 50% or lower. Transactions with a risk score exceeding 50% will be rejected and eligible for a refund per the procedures described in this policy. Amlbot.com screens transactions across the following risk categories: • Dark Service — coins associated with child exploitation, terrorist financing, or drug trafficking; • Dark Market — coins used for purchases on darknet marketplaces; • Scam — coins obtained through fraud or deceptive practices; • Mixer — coins processed through mixing services to obscure their origin; • Illegal Service — coins linked to illegal activities; • Ransom — coins obtained through ransomware or extortion; • Exchange Fraudulent — coins from exchanges associated with fraud, illegal activity, or government seizure; • Stolen — stolen coins; • Gambling — coins linked to unlicensed online gambling operations. There is no additional per-category threshold. The overall AML risk score determines acceptance or rejection.

For the purposes of AML compliance, AEXI may require users to undergo Know Your Customer (KYC) verification. By using the Stablecoin Exchange, the user confirms that they are acting as an individual (natural person) and not on behalf of a legal entity. Acceptable identification documents include: • International passport; • National ID card; • Driver's license. Proof of address (bank statement, utility bill, or government-issued document) may be required upon request from regulatory authorities or law enforcement. Video verification may be required in cases of elevated risk or upon request from regulatory authorities. AEXI does not operate bank card verification as fiat payment methods are not supported.

AEXI conducts AML screening at the point of deposit for each Stablecoin Exchange transaction. The full chain of transactions is monitored to assess risk. Transaction data and screening results are retained for up to three (3) years from the date of data submission. AEXI reserves the right to flag and manually review transactions that trigger risk indicators in its internal systems.

AEXI screens transactions against international sanctions designations across the following jurisdictions: • United States — OFAC (Office of Foreign Assets Control) sanctions list; • United Kingdom — OFSI (Office of Financial Sanctions Implementation) consolidated list; • Republic of Korea — MOFA (Ministry of Foreign Affairs) sanctions list; • Israel — NBCTF (National Bureau for Counter Terror Financing) sanctions list. Sender wallets flagged against any of these lists are rejected and, where applicable, eligible for a refund under the procedures in this policy. Sanctions lists are updated as necessary based on official publications from the respective authorities. AEXI does not conduct PEP (Politically Exposed Persons) screening or adverse media checks.

In the event that a transaction is rejected due to an AML risk score exceeding 50%, or for any other compliance reason, AEXI's policy is to return funds to the user in the vast majority of cases. Refund procedures: • Refunds are issued exclusively to the wallet address from which the original deposit was made; • Refunds are processed within three (3) business days; • The refund amount is calculated based on the received currency at the time of the refund, minus network (blockchain) transaction fees; • For transactions originating from sanctioned exchanges or services, the user must provide: (a) an unedited video showing them logging into their exchange account, demonstrating access to the deposit address; (b) a screenshot of the deposit screen showing the AEXI deposit address; • To confirm wallet ownership, the user must submit an unedited video through the contact form showing them accessing the wallet in question from the beginning of the video. AEXI may share transaction data, user information, and screening results with amlbot.com, regulatory authorities, or law enforcement upon legitimate request.

AEXI may freeze a user's ability to transact for up to ninety (90) business days in cases of suspected suspicious activity. Funds may be retained only upon receipt of a valid request from law enforcement authorities accompanied by confirmation of an open criminal investigation and a directive to withhold payment. AEXI cooperates with law enforcement authorities in accordance with applicable law and upon presentation of proper legal process.

AML/KYC data is processed in accordance with AEXI's Privacy Policy and applicable data protection regulations. Data shared with amlbot.com for screening purposes may include: wallet address, transaction amount, IP address, and contact information provided in the exchange request. AML/KYC data is retained for three (3) years from the date of submission. Users may request deletion of their AML/KYC data after one (1) year from the date of payment, provided that no pending requests or investigations exist from any party regarding the associated transaction. AML screening procedures are conducted confidentially. The existence and details of any screening or investigation are not disclosed to third parties except as required by law.

AEXI reserves the right to refuse service to any user at its sole discretion, including but not limited to cases where: • The AML risk score exceeds the established threshold; • The user fails to provide requested verification documents; • The user is unable or unwilling to confirm wallet ownership; • There are reasonable grounds to suspect involvement in money laundering, terrorist financing, or other illegal activity; • AEXI receives a directive from regulatory authorities or law enforcement; • The transaction involves a jurisdiction or service subject to sanctions. No explanation for refusal is required beyond what is mandated by applicable law.

All AEXI personnel involved in AML/KYC compliance receive comprehensive training on applicable laws, regulations, and internal procedures. Training is conducted upon onboarding and updated regularly to reflect current laws and regulatory requirements. Additional training is provided when new laws or regulations are adopted or when required by regulatory authorities.