Anti-Money Laundering Policy

1. Introduction and Commitment

NewCo Ltd. ("Axiom," "we," "our," or "us"), Company No: NEW123, registered at New Address 1, is committed to preventing money laundering, terrorist financing, and other financial crimes.

This Anti-Money Laundering (AML) Policy sets out our approach to detecting, preventing, and reporting suspicious activities in compliance with applicable laws and regulations, including:

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (UK)
• EU Anti-Money Laundering Directives (AMLD)
• Financial Action Task Force (FATF) Recommendations
• Proceeds of Crime Act 2002 (POCA)
• Terrorism Act 2000

2. Scope and Application

This policy applies to:

• All users of the Axiom platform (buyers and specialists)
• All employees, contractors, and agents of NewCo Ltd.
• All transactions processed through our platform
• All business relationships established through our services

We maintain a risk-based approach to AML compliance, applying enhanced measures where higher risks are identified.

3. Know Your Customer (KYC) Procedures

3.1 Customer Identification

We verify the identity of all users before they can access certain platform features. Our KYC process includes:

• Basic Verification: Email verification, phone number confirmation
• Identity Verification: Government-issued ID document verification via Sumsub
• Address Verification: Proof of address for specialists receiving payouts
• Enhanced Due Diligence: Additional checks for high-value transactions or high-risk indicators

3.2 Specialist Verification

All specialists must complete full KYC verification before:

• Listing services on the platform
• Receiving any payouts from completed work
• Accessing earnings above the verification threshold

3.3 Ongoing Monitoring

We continuously monitor accounts and transactions for suspicious activity. Verification may be requested again if there are significant changes to account activity or if initial verification documents expire.

4. Customer Due Diligence (CDD)

4.1 Standard Due Diligence

For all customers, we collect and verify:

• Full legal name
• Date of birth
• Residential address
• Nationality
• Government-issued identification

4.2 Enhanced Due Diligence (EDD)

Enhanced measures are applied in higher-risk situations, including:

• Politically Exposed Persons (PEPs) and their associates
• Customers from high-risk jurisdictions
• Unusual or complex transaction patterns
• High-value transactions exceeding specified thresholds
• Business relationships with unclear economic purpose

4.3 Simplified Due Diligence

Reduced verification may be applied to demonstrably low-risk situations, in accordance with regulatory guidance.

5. Transaction Monitoring

5.1 Automated Monitoring

We employ automated systems to monitor transactions for:

• Unusual transaction volumes or values
• Rapid or frequent transactions inconsistent with normal use
• Transactions with high-risk countries
• Patterns indicative of layering or structuring
• Mismatches between transaction activity and stated purpose

5.2 Manual Review

Flagged transactions are escalated to our compliance team for manual review. Accounts may be temporarily restricted pending investigation.

6. Sanctions and PEP Screening

6.1 Sanctions Screening

All users are screened against international sanctions lists, including:

• UK HM Treasury Sanctions List
• EU Consolidated Sanctions List
• US OFAC Sanctions Lists
• UN Security Council Sanctions List

6.2 PEP Identification

We screen users to identify Politically Exposed Persons (PEPs), their family members, and close associates. Enhanced due diligence is applied to all identified PEPs.

7. Record Keeping

We maintain comprehensive records in compliance with regulatory requirements:

• Customer Records: Identity documents, verification results, and account information - retained for 5 years after the business relationship ends
• Transaction Records: All payment and credit transactions - retained for 5 years after the transaction
• Suspicious Activity Reports: Internal records of all SARs filed - retained for 5 years
• Training Records: Employee AML training completion - retained for the duration of employment plus 5 years

Records are stored securely and made available to relevant authorities upon lawful request.

8. Suspicious Activity Reporting

8.1 Internal Reporting

Any employee who suspects money laundering or terrorist financing must immediately report to our Money Laundering Reporting Officer (MLRO). All reports are investigated promptly.

8.2 External Reporting

When required, we file Suspicious Activity Reports (SARs) with the relevant Financial Intelligence Unit, including:

• National Crime Agency (NCA) in the UK
• Relevant EU member state FIUs where applicable

8.3 Tipping Off

We are prohibited by law from informing customers that a SAR has been filed or that they are under investigation. Breaching this prohibition is a criminal offense.

9. High-Risk Activities and Prohibited Conduct

9.1 Prohibited Activities

The following activities are strictly prohibited on our platform:

• Using the platform to launder money or finance terrorism
• Providing false or misleading identity information
• Structuring transactions to avoid reporting thresholds
• Using accounts on behalf of undisclosed third parties
• Transactions involving sanctioned individuals or entities
• Any activity designed to obscure the source or destination of funds

9.2 Consequences

Violations of this policy may result in immediate account termination, forfeiture of funds, and referral to law enforcement authorities.

10. Training and Awareness

All relevant employees receive regular AML training, including:

• Recognition of suspicious activities and red flags
• Understanding of legal obligations and penalties
• Internal reporting procedures
• Customer due diligence requirements
• Updates on regulatory changes and emerging risks

11. Governance and Oversight

11.1 Money Laundering Reporting Officer (MLRO)

We have appointed a qualified MLRO responsible for:

• Overseeing AML compliance program
• Receiving and investigating internal reports
• Filing SARs with relevant authorities
• Ensuring adequate training for staff
• Reporting to senior management and board

11.2 Regular Review

Our AML policies and procedures are reviewed at least annually, or more frequently when there are significant regulatory changes or identified deficiencies.

12. User Obligations

By using our platform, you agree to:

• Provide accurate and truthful identity information
• Promptly update your information if it changes
• Cooperate with verification requests
• Not use the platform for illegal purposes
• Report any suspicious activity you encounter
• Only transact on your own behalf, not for third parties (unless disclosed)

13. Account Restrictions and Termination

We reserve the right to:

• Delay or refuse transactions pending verification
• Suspend accounts where suspicious activity is detected
• Terminate accounts that violate this policy
• Freeze funds subject to investigation or legal proceedings
• Decline service to individuals from high-risk jurisdictions

14. Changes to This Policy

We may update this AML Policy to reflect changes in law, regulation, or our business practices. Significant changes will be communicated to users. Continued use of our platform constitutes acceptance of the updated policy.