AML & Sanctions Policy

Xynex is committed to preventing the use of its platform for money laundering, terrorist financing, sanctions evasion, or other financial crime. This policy summarises the controls we apply across onboarding, transaction monitoring, sanctions screening, reporting, and merchant suspension.

This policy applies to every merchant, beneficial owner, payout beneficiary, customer transaction, and partner that interacts with the Xynex platform.

Every merchant must complete KYB before processing live transactions. KYB collects and verifies:

• Legal entity name, registration number, country of incorporation.
• Registered and operating addresses.
• Identification of all ultimate beneficial owners (≥ 25% ownership or control).
• Government-issued identity documents for owners and authorised signatories.
• Source of funds and source of business activity.
• A description of products / services sold and target markets.

Xynex applies enhanced due diligence to higher-risk industries, jurisdictions, and ownership structures.

Merchants, beneficial owners, payout beneficiaries and (where reasonable) payer wallet addresses are screened on onboarding and on an ongoing basis against the OFAC SDN list, EU consolidated list, UK HMT list, UN Security Council list and other lists Xynex deems relevant. We do not provide services to persons or entities resident in or operating from comprehensively sanctioned jurisdictions.

Xynex does not process payments for, and will immediately terminate any merchant engaged in, any of the following:

• Sale of illegal drugs, narcotics, controlled substances or paraphernalia.
• Sale of weapons, firearms, ammunition, or explosives where unlicensed.
• Child sexual abuse material or human trafficking.
• Ransomware, malware, hacking services, cyber-extortion tooling.
• Mixers, tumblers, privacy-coin laundering services, or darknet markets.
• Unlicensed financial services, securities offerings, gambling, or money-services activity.
• Counterfeit goods, intellectual-property infringement, illegal wildlife trade.
• Funding for terrorism, sanctions evasion, or politically violent activity.
• Any activity unlawful in the merchant's or customer's jurisdiction.

Xynex monitors transactions in real time using risk rules covering velocity, amount thresholds, geographic patterns, address-clustering signals, and known illicit-actor heuristics. Alerts are investigated by our compliance operations team and may result in additional documentation requests, transaction holds, or account suspension.

Where legally required, Xynex files Suspicious Activity Reports / Suspicious Transaction Reports with the relevant Financial Intelligence Unit and cooperates with lawful requests from regulators and law-enforcement authorities. Merchants are reminded that "tipping off" — informing a subject that a report has been filed — may itself be a criminal offence in their jurisdiction.

KYB documentation, transaction records, and compliance investigation files are retained for at least 5 years (or longer where local law requires) after the end of the business relationship.

Xynex staff with access to merchant or transaction data receive AML/CTF and sanctions training on hire and at least annually. The compliance program is overseen by a designated Money Laundering Reporting Officer (MLRO) and is independently reviewed at least once per year.

Operating on Xynex does not transfer your own AML, sanctions, licensing, tax, or consumer-protection obligations to us. You must run your own program where required by your regulator and you must cooperate with reasonable compliance information requests from Xynex.

AML / compliance contact: compliance@xynex.app. See also our Terms of Service andPrivacy Policy.