Apotoe Trading is committed to preventing the use of its platform (the "Platform") for money laundering, terrorist financing, sanctions evasion, or any other financial crime. This policy summarises the framework we apply and the obligations of users.

This policy applies to every partner, buyer, warehouse operator, representative, and any counterparty that transacts through the Platform, and to all wallet, brokerage, settlement, and delivery activity we facilitate.

Our controls are designed to align with applicable AML, counter-terrorist financing (CTF), and sanctions rules in the jurisdictions we operate in, and are adapted as the regulatory environment evolves.

We apply a risk-based approach, meaning the depth of checks and monitoring is proportionate to the assessed risk of a user, commodity, geography, transaction size, and pattern of activity.

Individual users may be asked to provide government-issued identification, proof of address, contact information, and other data reasonably required to verify identity.

Companies may be asked to provide registration documents, tax identification, ownership information, and details of directors and beneficial owners.

We seek to identify and verify natural persons who ultimately own or control corporate users, in line with applicable thresholds and guidance.

Users and, where relevant, their beneficial owners may be screened against sanctions lists and against politically exposed persons (PEP) references.

Higher-risk users, transactions, or geographies may attract enhanced due diligence, including additional documentation, source-of-funds evidence, and management approval.

We monitor wallet activity, orders, trade contracts, and settlements for patterns that may indicate unusual or suspicious behaviour.

We may apply thresholds, holds, or additional verification steps on cash-in, cash-out, or high-value trade activity.

Users must not use the Platform to layer, structure, or otherwise disguise the origin of funds; to move value on behalf of undisclosed third parties; or to circumvent sanctions or export controls.

We do not knowingly onboard or transact with individuals or entities on applicable sanctions lists, or with counterparties in jurisdictions where doing so would breach applicable law.

Where required, we file reports with competent authorities and cooperate fully with their requests, in accordance with applicable law.

Reports made to authorities and related investigations are treated confidentially. We may be legally prohibited from disclosing them.

Verification records, transaction records, and monitoring outputs are retained for the periods required by applicable law.

Responsibility for the AML programme sits with senior management, supported by dedicated compliance resources and independent review.

Personnel involved in compliance, operations, and user support receive AML training appropriate to their role, refreshed periodically.

Where third-party providers assist with verification, screening, or monitoring, they are engaged under appropriate contractual and data-protection controls.

Users must supply accurate information promptly when requested, keep their profile and verification data current, and respond to reasonable follow-up questions.

We may pause activity, decline transactions, freeze balances, suspend or terminate accounts, and take other actions where a user fails to meet AML requirements or where activity presents unacceptable risk.

We coordinate with banks, mobile-money operators, and payment processors so that funds moving through the Platform meet their AML obligations as well as ours.

AML-related data is handled in accordance with our Privacy Policy and is used only for compliance, risk management, and legal purposes.

This policy is reviewed regularly and updated as our services, geographies, or the regulatory environment change.

Compliance questions can be sent to partners@apotoe.com.