AML Policy

Anti-Money Laundering (AML) & Counter-Terrorist Financing Policy

Effective Date: September 29, 2026
Last Updated: September 29, 2026

1. Introduction

Azness is committed to maintaining a secure and responsible digital asset platform and to preventing its services from being misused for money laundering, terrorist financing, fraud, sanctions evasion, or other illicit financial activities.

This Anti-Money Laundering and Counter-Terrorist Financing Policy (“AML Policy”) describes the framework and controls Azness applies to identify, assess, monitor, and mitigate financial crime risks associated with its platform and services.

Azness follows a risk-based approach and seeks to align its financial crime controls with applicable laws, regulatory requirements, and internationally recognized standards, including relevant principles developed by the Financial Action Task Force (FATF).

2. Purpose of This Policy

The purpose of this AML Policy is to establish controls designed to:

  • Prevent the misuse of Azness for money laundering and terrorist financing

  • Identify and verify customers and, where applicable, beneficial owners

  • Assess and manage customer and transaction risk

  • Detect potentially suspicious activity

  • Monitor transactions and account activity

  • Screen customers and transactions against applicable sanctions requirements

  • Maintain appropriate records

  • Cooperate with competent authorities where legally required

  • Continuously improve Azness's financial crime prevention program

3. Risk-Based Approach

Azness applies a risk-based approach to AML and financial crime prevention.

The level of due diligence and monitoring applied to a customer or transaction may vary depending on factors such as:

  • Customer profile

  • Geographic exposure

  • Products and services used

  • Transaction activity

  • Source of funds or wealth, where appropriate

  • Transaction patterns

  • Blockchain and wallet activity

  • Sanctions and screening results

  • Other relevant financial crime risk indicators

Higher-risk situations may be subject to enhanced due diligence, additional verification, increased monitoring, restrictions, or other appropriate measures.

4. Know Your Customer (KYC)

Azness may require customers to complete identity verification before accessing certain products or services.

Depending on the applicable requirements and risk level, verification may include:

  • Full legal name

  • Date of birth

  • Residential address

  • Nationality

  • Government-issued identification

  • Proof of address

  • Selfie or liveness verification

  • Source of funds or source of wealth information

  • Information regarding the purpose and nature of the customer relationship

Azness may request additional information when required to understand and manage financial crime risks.

Customers are responsible for providing accurate, complete, and up-to-date information.

5. Customer Due Diligence

Azness conducts customer due diligence in accordance with applicable requirements and its risk-based compliance framework.

Customer due diligence may be performed:

  • When establishing an account or business relationship

  • When required by applicable law

  • When customer information changes

  • When transaction activity creates additional risk

  • When Azness has concerns regarding potential financial crime

  • At other appropriate points based on the customer's risk profile

Azness may decline, restrict, suspend, or terminate an account where required information cannot be satisfactorily verified or where continuing the relationship presents unacceptable risk.

6. Enhanced Due Diligence

Azness may apply Enhanced Due Diligence (“EDD”) to customers, transactions, or relationships presenting higher financial crime risk.

EDD may include:

  • Additional identity verification

  • Verification of source of funds or source of wealth

  • Additional information regarding the purpose of transactions

  • Additional review of wallet or blockchain activity

  • Increased transaction monitoring

  • Additional compliance review

  • Senior management or compliance approval where appropriate

7. Sanctions Screening

Azness maintains controls designed to identify customers, transactions, wallets, or other activities that may present sanctions-related risks.

Where required, Azness may screen relevant information against applicable sanctions lists and other legally relevant screening sources.

Where a potential match or sanctions concern is identified, Azness may place temporary restrictions on an account or transaction while the matter is reviewed.

8. Transaction Monitoring

Azness uses risk-based monitoring processes to identify unusual or potentially suspicious activity.

Monitoring may consider factors including:

  • Unusual transaction patterns

  • Rapid movement of digital assets

  • Significant changes in account activity

  • Transactions inconsistent with a customer's expected profile

  • Exposure to higher-risk addresses or services

  • Attempts to circumvent platform controls

  • Potential fraud indicators

  • Sanctions-related indicators

  • Other activity identified through automated or manual monitoring

Monitoring systems and procedures may be updated as financial crime risks and technologies evolve.

9. Blockchain and Wallet Monitoring

Because digital asset transactions are recorded on public or otherwise observable blockchain networks, Azness may use blockchain analytics and transaction-monitoring tools to assess wallet and transaction risk.

Where appropriate, Azness may review transaction history, wallet exposure, and other blockchain-related information to identify potential financial crime risks.

Transactions involving addresses or services associated with illicit activity may be subject to additional review or restrictions.

10. Suspicious Activity

Where Azness identifies activity that may involve money laundering, terrorist financing, fraud, sanctions violations, or other unlawful activity, the activity may be reviewed by the appropriate compliance personnel.

Where required by applicable law, Azness may submit reports or information to competent authorities or financial intelligence authorities.

Azness may also restrict or suspend relevant accounts, transactions, or services where legally permitted or required.

Azness does not disclose information about suspicious activity reports or related investigations where disclosure is prohibited by applicable law.

11. Travel Rule and Transfer Information

Where applicable laws and regulatory requirements require the collection or transmission of information relating to transfers of digital assets, Azness will implement appropriate controls to collect, verify, retain, and transmit the required information.

The information required may depend on the jurisdictions, counterparties, transaction type, and applicable regulatory requirements.

12. Prohibited and Restricted Activities

Azness may prohibit or restrict activities that present unacceptable legal, regulatory, financial crime, or security risks.

This may include activities involving:

  • Money laundering

  • Terrorist financing

  • Sanctions evasion

  • Fraud

  • Stolen assets

  • Proceeds of crime

  • Identity fraud

  • Unauthorized use of another person's account

  • Attempts to circumvent AML or KYC controls

  • Other unlawful activities

Azness may take appropriate action where prohibited or suspicious activity is identified.

13. Record Keeping

Azness maintains appropriate records relating to customer identification, verification, transactions, compliance reviews, and other relevant information in accordance with applicable legal and regulatory requirements.

Records may be retained for the period required by applicable law.

Access to compliance information is restricted to authorized personnel and parties with a legitimate legal or operational need.

14. Data Protection and Confidentiality

Azness recognizes the importance of protecting customer information.

Information collected for AML, KYC, sanctions screening, transaction monitoring, or compliance purposes is handled in accordance with applicable privacy and data protection requirements.

Azness may disclose information to competent authorities, regulators, law enforcement agencies, service providers, or other parties where disclosure is legally required or otherwise permitted.

15. Compliance Program

Azness maintains an AML and financial crime compliance framework that may include:

  • Customer identification and verification

  • Risk assessment

  • Transaction monitoring

  • Sanctions screening

  • Blockchain analytics

  • Suspicious activity investigation

  • Compliance reviews

  • Employee training

  • Internal controls

  • Record keeping

  • Periodic review and improvement of AML procedures

Azness may use automated systems, third-party compliance providers, blockchain analytics providers, and manual reviews as part of its financial crime prevention framework.

16. Compliance Training

Relevant Azness personnel may receive training appropriate to their responsibilities relating to AML, CFT, sanctions, fraud prevention, customer due diligence, and financial crime risk management.

Training and procedures may be updated as applicable requirements and emerging risks change.

17. Ongoing Monitoring and Review

Azness periodically reviews its AML framework to identify emerging risks and opportunities to improve its controls.

The AML Policy and related procedures may be updated to reflect:

  • Changes in applicable laws and regulations

  • Regulatory guidance

  • Changes in Azness products or services

  • Emerging financial crime risks

  • Changes in technology

  • Internal risk assessments

  • Lessons identified through monitoring and investigations

18. Customer Cooperation

Customers are expected to provide accurate information and cooperate with reasonable verification and compliance requests.

Failure to provide requested information may result in delays, restrictions, suspension, or termination of certain services where appropriate.

19. Account Restrictions and Termination

Azness reserves the right, subject to applicable law and its terms of service, to restrict, suspend, or terminate accounts or transactions where:

  • Required verification cannot be completed

  • Information provided is inaccurate or misleading

  • Suspicious or prohibited activity is identified

  • Sanctions concerns arise

  • The account presents unacceptable financial crime risk

  • Continued access would create legal or regulatory concerns

Azness may not disclose detailed information about certain restrictions or investigations where doing so could compromise compliance processes or violate applicable law.

20. Governance and Responsibility

Azness is committed to maintaining appropriate governance and oversight of its AML and financial crime prevention framework.

Relevant compliance responsibilities may include:

  • Maintaining AML policies and procedures

  • Conducting risk assessments

  • Monitoring customer and transaction activity

  • Reviewing alerts and investigations

  • Maintaining appropriate records

  • Escalating material compliance concerns

  • Updating controls as risks evolve

The scope of these responsibilities may vary depending on Azness's organizational structure, products, jurisdictions, and applicable regulatory requirements.

21. Policy Updates

Azness may update this AML Policy from time to time to reflect changes in applicable requirements, regulatory guidance, technology, products, services, or financial crime risks.

The latest version will be published on the Azness website where appropriate.

22. Contact

For AML, compliance, or financial crime-related inquiries, please contact:

Compliance Team
Azness
Email: compliance@azness.com


Important Notice

This AML Policy describes Azness's intended financial crime prevention framework and should be read together with Azness's Terms of Service, Privacy Policy, KYC Policy, Risk Disclosure, and other applicable policies.

The application of specific AML/CFT requirements may depend on the jurisdiction in which Azness operates, the services provided, and the applicable legal and regulatory framework.