International Cryptoasset, Fiat Services, AML/KYC, Tax & Regulatory Compliance Policy

Asset Flow Limited (“Asset Flow”, “we”, “us” or “our”) is committed to maintaining appropriate standards for customer identification, financial-crime prevention, transaction monitoring, regulatory compliance, tax transparency, fraud prevention and responsible operation across the jurisdictions in which our services are made available.

This policy applies to customers who use Asset Flow’s cryptocurrency, digital-asset, wallet, payment, deposit, withdrawal, conversion or supported fiat-currency services. Fiat services and any associated banking or payment services are restricted-access services. They are not automatically available to every registered user. Access is limited to qualified Affiliate Investors who maintain an active Group Investor status/account and who satisfy all applicable eligibility, verification, KYC/AML, compliance, jurisdictional, account-status and service requirements.

Asset Flow’s available fiat services may include, subject to availability and applicable eligibility requirements:

Additional currencies, countries or financial services may be introduced or discontinued from time to time.

The availability of a particular fiat currency does not by itself mean that Asset Flow provides regulated financial services in every jurisdiction where that currency is used, nor that every registered user may access that currency or any associated banking or payment facility. Services are subject to geographic availability, Affiliate Investor qualification, active Group Investor status/account, customer eligibility, applicable laws, regulatory requirements, payment-provider requirements and Asset Flow’s internal risk controls.

This policy covers:

• Customer Identification and Verification (KYC/CDD)
• Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF)
• Enhanced Due Diligence (EDD)
• Source of Funds and Source of Wealth verification
• Transaction monitoring and risk management
• Financial-crime prevention
• Fraud prevention and detection
• Sanctions compliance and screening
• Politically Exposed Person (PEP) screening
• Suspicious activity monitoring, escalation and reporting
• Customer and transaction recordkeeping
• Cryptocurrency and fiat-currency compliance
• Tax information and reporting obligations
• Cross-border transaction compliance
• Regulatory and law-enforcement cooperation
• Customer responsibilities and regulatory disclosures
• Data protection and confidentiality

Asset Flow operates a risk-based compliance framework. The specific requirements applicable to a customer may differ according to their country of residence, location, nationality where relevant, transaction activity, source of funds, services used, payment method, risk profile and applicable law.

Where required, Asset Flow may apply additional verification, monitoring, reporting, transaction limits, restrictions or disclosure requirements.

Customers acknowledge that their use of Asset Flow may be subject to the laws and regulatory requirements applicable to:

• the customer’s country or jurisdiction of residence;
• the jurisdiction in which a transaction takes place;
• the jurisdiction from which or to which funds or digital assets are transferred;
• the jurisdiction of a payment provider, banking partner or financial institution;
• the customer’s applicable tax jurisdiction;
• sanctions and financial-crime regimes;
• applicable international information-sharing and tax-transparency frameworks; and
• any other jurisdiction whose laws are applicable to the relevant service or transaction.

Asset Flow may collect, verify, monitor, retain, process and disclose customer information where reasonably necessary or legally required for AML/CTF, fraud prevention, sanctions compliance, regulatory compliance, tax reporting, law-enforcement cooperation or other legitimate compliance purposes.

This policy should be read together with Asset Flow’s Terms of Service, Privacy Policy, Risk Management Policy, Security Policy and other applicable compliance and operational procedures.

Asset Flow recognises that regulatory obligations relating to cryptocurrency, digital assets, fiat services, financial crime and taxation vary between jurisdictions.

Depending on the nature of the service and the customer’s circumstances, Asset Flow may be required to maintain controls designed to address applicable requirements in jurisdictions including:

Asset Flow prohibits the use of its services for:

• Money laundering
• Terrorist financing
• Fraud
• Sanctions evasion
• Proceeds of criminal activity
• Identity theft
• Financial crime
• Other unlawful activity

Asset Flow’s AML/CTF framework is designed to identify, assess and manage financial-crime risks associated with customers, accounts, fiat transactions, cryptocurrency transactions, wallet activity, deposits, withdrawals and other platform activity.

Asset Flow applies a risk-based approach rather than assuming that all customers or transactions present the same level of risk.

Where required by applicable law or regulation, Asset Flow will designate an appropriately qualified compliance officer, Money Laundering Reporting Officer (MLRO), or equivalent responsible person.

Responsibilities may include:

• Monitoring AML/CTF compliance
• Reviewing escalated suspicious activity
• Overseeing transaction monitoring
• Maintaining appropriate compliance records
• Coordinating internal escalation procedures
• Coordinating suspicious-activity reporting where legally required
• Overseeing compliance training
• Reviewing the effectiveness of financial-crime controls
• Escalating material deficiencies to appropriate management
• Maintaining appropriate confidentiality regarding investigations and reports

The responsible compliance function will have appropriate authority and access to information necessary to perform these responsibilities.

Asset Flow applies Customer Due Diligence (CDD) based on the customer’s risk profile, jurisdiction, transaction activity and services requested.

Individuals

Depending on the circumstances, customers may be required to provide:

• Full legal name
• Date of birth
• Residential address
• Country of residence
• Nationality where required
• Email address
• Telephone number
• Government-issued photographic identification
• Proof of residential address
• Additional information reasonably required to verify identity or assess risk

Companies and Other Legal Entities

Asset Flow may request:

• Legal name
• Registered address
• Incorporation information
• Nature and purpose of the business
• Directors or equivalent controlling persons
• Beneficial ownership information
• Identification documents for relevant individuals
• Source of Funds
• Source of Wealth
• Corporate documentation
• Additional information reasonably required for verification

The information required may vary according to the customer’s jurisdiction, risk profile, transaction activity and applicable regulatory requirements.

Asset Flow may verify customer information through documentary and electronic methods.

Verification may include:

• Government-issued photographic identification
• Proof of residential address
• Electronic identity verification
• Email verification
• Telephone verification
• Identity-screening databases
• Sanctions screening
• PEP screening
• Adverse-media screening
• Beneficial ownership verification

Additional verification may be required where information appears inconsistent, incomplete, suspicious or insufficient to establish identity.

Asset Flow may restrict deposits, withdrawals, conversions, fiat services or other platform functions until required verification has been completed.

Customers and transactions may be assigned different levels of monitoring or verification based on factors including:

• Country or jurisdiction
• Nature of activity
• Transaction volume
• Transaction frequency
• Source of Funds
• Source of Wealth
• Ownership structure
• Sanctions exposure
• PEP status
• Adverse media
• Unusual transaction behaviour
• Payment method
• Wallet activity
• Use of higher-risk services or jurisdictions
• Cross-border activity

Higher-risk customers or transactions may be subject to Enhanced Due Diligence.

Verification requirements, transaction limits and access to particular services may therefore vary between customers.

Verification is a compliance control and does not constitute a guarantee of unrestricted access to Asset Flow services.

Where a customer, transaction or activity presents elevated financial-crime risk, Asset Flow may conduct Enhanced Due Diligence (EDD).

EDD may include:

• Additional identity documentation
• Source of Funds verification
• Source of Wealth verification
• Additional information concerning transaction purpose
• Beneficial ownership verification
• Additional information concerning business activities
• Independent documentary evidence
• Enhanced transaction monitoring
• Additional management or compliance approval

Asset Flow may decline, restrict, delay or suspend services where required information cannot be satisfactorily established.

Asset Flow may request information demonstrating the legitimate origin of funds or digital assets.

Depending on the circumstances, evidence may include:

• Bank statements
• Payslips
• Employment documentation
• Business records
• Investment statements
• Sale agreements
• Tax documentation
• Inheritance documentation
• Cryptocurrency transaction records
• Wallet transaction history
• Exchange statements
• Other reliable supporting documentation

The evidence required will depend on the customer’s risk profile and the nature and size of the transaction.

Fiat services and any associated banking or payment services made available through the Platform are restricted-access services and are not automatically available to all registered users. Access is limited to qualified Affiliate Investors who maintain an active Group Investor status/account and who satisfy all applicable eligibility, verification, KYC/AML, compliance, jurisdictional and account-status requirements.

Where available, such services may include fiat deposits, fiat withdrawals, bank transfers, bank or payment-account services, currency conversion, supported fiat currencies, payment processing, and other related payment services arranged through third-party banking or payment service providers.

Asset Flow may provide supported fiat services involving currencies such as GBP, USD, CAD, AUD and EUR. Fiat transactions may include, where available and where the customer satisfies the eligibility requirements set out in this policy:

• Fiat deposits
• Fiat withdrawals
• Bank transfers
• Bank or payment-account services
• Cryptocurrency-to-fiat conversion
• Fiat-to-cryptocurrency conversion
• Account balance conversion
• Payment processing
• Other supported payment, settlement or third-party banking or payment-provider services

Availability of a currency, payment method, banking facility or service may depend on:

• Affiliate Investor qualification
• Active Group Investor status/account
• Customer location and jurisdiction
• Verification, KYC/AML and compliance status
• Applicable law and regulatory requirements
• Payment-provider availability and requirements
• Banking-partner requirements
• Technical availability
• Transaction risk
• Currency availability
• Internal risk controls

Asset Flow Limited does not itself operate as a bank, deposit-taking institution or regulated banking institution by reason of making restricted fiat or payment services available through the Platform. Where banking or payment services are made available, they are provided subject to the terms, availability and requirements of the relevant third-party provider.

Asset Flow may apply additional verification or transaction monitoring to fiat transactions where required. Fiat transactions may also be subject to processing times, limits, fees, intermediary requirements and restrictions imposed by relevant payment providers or financial institutions.

Asset Flow Limited does not guarantee that any particular fiat or banking service will remain available and may restrict, suspend or discontinue access where eligibility requirements are no longer satisfied, including where Affiliate Investor or Group Investor status becomes inactive, expires, is suspended, fails verification or otherwise no longer satisfies the Platform’s eligibility requirements, or where required for regulatory, compliance, security, risk-management or service-provider reasons. Maintaining an active Group Investor status/account is a continuing condition of eligibility for access to the Platform’s restricted fiat and associated banking/payment services.

Asset Flow monitors account and transaction activity using a risk-based approach.

Monitoring may consider:

• Transaction size
• Transaction frequency
• Transaction patterns
• Fiat deposits and withdrawals
• Cryptocurrency deposits and withdrawals
• Wallet activity
• Changes in normal account behaviour
• Cross-border transfers
• Transfers involving higher-risk jurisdictions
• Rapid movement of funds
• Multiple accounts displaying connected activity
• Attempts to avoid compliance controls
• Unusual use of cryptocurrency or fiat services
• Other indicators of potential financial crime

Automated monitoring may generate alerts for additional review.

An alert does not necessarily mean that a customer has engaged in unlawful activity. It may simply require additional review or information.

Potential indicators requiring further review may include:

Customer Information

• Refusal to provide required identification
• False, inconsistent or apparently altered documentation
• Information that cannot reasonably be verified
• Unexplained changes to customer information
• Unclear beneficial ownership

Transaction Behaviour

• Transactions inconsistent with the customer’s stated circumstances
• Unusually large or rapid transactions
• Rapid movement of assets through multiple accounts or wallets
• Repeated transactions apparently designed to avoid monitoring
• Unexplained transfers involving higher-risk jurisdictions
• Activity with no apparent legitimate economic purpose

Attempts to Circumvent Controls

• Attempts to avoid verification requirements
• Attempts to structure transactions to avoid applicable monitoring or reporting
• Use of another person to conduct transactions without adequate explanation
• Attempts to conceal the source or destination of funds
• Attempts to circumvent sanctions or other restrictions

The presence of a red flag does not by itself establish criminal activity. It may result in additional due diligence, investigation or escalation.

Where Asset Flow has knowledge, suspicion or reasonable grounds for suspicion of money laundering, terrorist financing or other reportable financial crime, the matter may be escalated in accordance with applicable law.

Where a legal reporting obligation applies, Asset Flow may submit a suspicious-activity report or equivalent report to the appropriate competent authority.

The relevant reporting authority may differ according to jurisdiction. For example, applicable reporting channels may include relevant financial-intelligence or law-enforcement authorities in the United Kingdom, United States, Canada, Australia, European jurisdictions or other applicable countries.

Asset Flow will not disclose the existence or details of a suspicious-activity report where disclosure is prohibited by applicable law.

Customers should therefore understand that Asset Flow may be unable to explain the complete reason for certain compliance restrictions, investigations or delays.

Asset Flow may temporarily restrict, suspend or terminate an account or particular service where necessary to:

• Complete customer verification
• Conduct Enhanced Due Diligence
• Investigate suspicious activity
• Comply with legal or regulatory requirements
• Respond to a lawful authority request
• Address sanctions concerns
• Prevent fraud or financial crime
• Protect customers or the platform
• Comply with payment-provider requirements
• Prevent misuse of the platform
• Address inactive, expired, suspended or failed Affiliate Investor or Group Investor status
• Apply eligibility, verification, compliance or account-status requirements applicable to restricted fiat or associated banking/payment services

Eligibility for restricted fiat and associated banking or payment services may be suspended, restricted or withdrawn where the customer’s Affiliate Investor or Group Investor status becomes inactive, expires, is suspended, fails verification or otherwise no longer satisfies the Platform’s eligibility requirements.

Where permitted by law, Asset Flow will provide appropriate information regarding restrictions.

However, Asset Flow may be legally prohibited from disclosing information concerning investigations, suspicious-activity reports, law-enforcement requests or other confidential compliance matters.

Asset Flow will cooperate with lawful requests from competent authorities, regulators, financial-intelligence units, law-enforcement agencies and other authorised bodies.

Where legally required, Asset Flow may provide information relating to:

• Customer identity
• Account activity
• Transaction history
• Wallet addresses
• Fiat transactions
• Cryptocurrency transactions
• Deposit and withdrawal records
• Verification documentation
• Source-of-Funds information
• Source-of-Wealth information
• Relevant compliance records
• Tax-reporting information

Information will be disclosed in accordance with applicable law and appropriate legal process.

Asset Flow will maintain appropriate records relating to customer identification, verification, transactions, compliance reviews and other activities where required by applicable law.

Records may include:

• Customer identification information
• Verification results
• CDD and EDD records
• Beneficial ownership information
• Source-of-Funds documentation
• Source-of-Wealth documentation
• Fiat transaction records
• Cryptocurrency transaction records
• Wallet addresses
• Compliance alerts
• Investigation records
• Regulatory communications
• Suspicious-activity reporting records
• Relevant tax-reporting information

Records will be retained for the periods required by applicable legislation and regulatory requirements.

Asset Flow does not determine a customer’s personal tax liability.

Tax treatment of cryptocurrency and fiat transactions varies between jurisdictions and may depend on the customer’s:

• Country of residence
• Tax residency
• Type of asset
• Acquisition method
• Disposal method
• Transaction history
• Income
• Gains or losses
• Business activities
• Investment activities
• Applicable tax legislation

A cryptocurrency transaction that creates a taxable event in one jurisdiction may be treated differently in another.

Similarly, the conversion or withdrawal of cryptocurrency into GBP, USD, CAD, AUD or EUR does not automatically determine the amount of tax payable.

Customers are responsible for determining their own tax obligations and obtaining independent professional tax advice where appropriate.

For UK customers, cryptoassets are generally treated as assets rather than traditional currency.

Depending on the circumstances, Capital Gains Tax may be relevant when cryptoassets are disposed of. A disposal may include:

• Selling cryptocurrency for GBP
• Exchanging one cryptoasset for another
• Using cryptocurrency to purchase goods or services
• Certain gifts or transfers of cryptoassets

The taxable gain may differ substantially from the amount withdrawn or converted through Asset Flow.

For example, a customer converting cryptocurrency worth £89,890 into GBP has £89,890 of disposal proceeds for that transaction; this does not automatically mean that £89,890 is the customer’s taxable gain.

The customer’s actual tax position depends on acquisition cost, allowable expenses, losses, previous transactions and other applicable HMRC rules.

Not all cryptocurrency receipts are necessarily treated as capital gains.

Depending on the jurisdiction and circumstances, tax may apply to cryptocurrency received through activities such as:

• Employment
• Mining
• Staking
• Airdrops
• Lending
• DeFi arrangements
• Business activities
• Professional or financial trading activities
• Other income-generating activities

The tax treatment depends on the underlying facts and applicable legislation.

The description of an activity as “trading”, “investment” or another category by Asset Flow or a customer does not by itself determine the customer’s tax treatment.

Customers subject to United States taxation are responsible for determining the tax treatment of their cryptocurrency and fiat transactions under applicable federal, state and local requirements.

Depending on the circumstances, taxable events may arise from activities including:

• Sale of digital assets
• Exchange of digital assets
• Conversion into fiat currency
• Use of digital assets for goods or services
• Receipt of digital assets as income
• Staking or other reward activities
• Other taxable transactions

Asset Flow does not determine whether a particular transaction is taxable for a customer.

Customers should maintain appropriate records and obtain independent tax advice where necessary.

Customers subject to Canadian taxation are responsible for determining the applicable tax treatment of their cryptocurrency and fiat transactions.

Depending on the circumstances, cryptocurrency activity may have income or capital-gain implications.

Customers should maintain records of acquisitions, disposals, conversions, transfers, fees, proceeds and other relevant transactions and should obtain independent Canadian tax advice where appropriate.

Customers subject to Australian taxation are responsible for determining the applicable treatment of their cryptocurrency transactions under Australian tax requirements.

Depending on the circumstances, cryptocurrency activity may result in capital gains, ordinary income or other tax consequences.

Customers should maintain appropriate transaction records and obtain independent Australian tax advice where required.

Customers subject to taxation in European or other international jurisdictions are responsible for determining their own tax obligations.

Tax treatment may differ substantially between individual countries, including countries using EUR.

Asset Flow does not determine whether a particular transaction is taxable in a customer’s country.

Customers should consult an appropriately qualified tax professional in their country of tax residence where necessary.

Asset Flow recognises the development of international tax-transparency frameworks applicable to cryptoasset service providers.

Where Asset Flow falls within the scope of a relevant reporting regime, it may be required to collect, verify, retain and report customer or transaction information to the applicable tax authority or other competent authority.

Such frameworks may include:

• The OECD Crypto-Asset Reporting Framework (CARF)
• Applicable UK CARF implementation requirements
• Applicable European reporting requirements
• Applicable national tax-reporting frameworks
• Other international information-exchange or tax-transparency arrangements

Reporting requirements may apply to customer identification information, tax-residency information and relevant transaction information.

Tax reporting does not mean that Asset Flow determines the customer’s tax liability.

Customers should maintain complete records of their cryptoasset and fiat activity.

Records may include:

• Deposit dates
• Investment amounts
• Fiat currency used
• Cryptoassets acquired or received
• Quantity of cryptoassets
• Fiat value at relevant transaction times
• Acquisition costs
• Disposal values
• Crypto-to-crypto exchanges
• Cryptocurrency-to-fiat conversions
• Fiat deposits
• Fiat withdrawals
• Cryptocurrency withdrawals
• Transaction and network fees
• Wallet transfers
• Transaction hashes or references
• Gains and losses
• Relevant account statements

Asset Flow may provide account statements or transaction information to assist customers with their own recordkeeping.

Customers remain responsible for determining their tax position, filing required returns and paying taxes that are legally due.

Asset Flow may screen customers, transactions, wallet activity and counterparties against applicable sanctions lists and restrictions.

Where appropriate, screening may consider sanctions regimes administered by relevant authorities, including applicable authorities in:

• The United Kingdom
• United States
• Canada
• Australia
• European jurisdictions
• Other applicable jurisdictions

Asset Flow may restrict or reject transactions where required by applicable sanctions laws, regulations or internal risk controls.

Asset Flow may implement controls designed to detect and prevent:

• Account takeover
• Identity fraud
• Payment fraud
• Transaction fraud
• Money laundering
• Terrorist financing
• Sanctions evasion
• Social-engineering attacks
• Unauthorised transactions
• Suspicious wallet activity
• Other forms of financial crime

Customers may be contacted or required to complete additional verification where activity presents a potential security or financial-crime concern.

Asset Flow will handle customer information in accordance with applicable data-protection and privacy requirements.

Information obtained for KYC, AML/CTF, fraud prevention, sanctions screening, regulatory compliance or tax reporting will be accessed, processed and disclosed in accordance with applicable law.

Depending on the customer’s jurisdiction and the services used, information may be processed or disclosed where necessary for:

• Identity verification
• Financial-crime prevention
• Regulatory compliance
• Tax reporting
• Payment processing
• Fraud prevention
• Law-enforcement cooperation
• Legal obligations

Certain compliance information, including suspicious-activity reports and law-enforcement requests, may be subject to legal confidentiality requirements.

Asset Flow will maintain appropriate compliance and financial-crime training for relevant personnel.

Training may cover:

• AML/CTF obligations
• Customer Due Diligence
• Enhanced Due Diligence
• Sanctions
• Fraud prevention
• Transaction monitoring
• Financial-crime red flags
• Suspicious-activity escalation
• Reporting obligations
• Recordkeeping
• Data confidentiality
• Customer protection
• Applicable regulatory developments

Training will be reviewed periodically and updated where material regulatory or operational changes occur.

Asset Flow will periodically assess the effectiveness of its compliance framework.

Where appropriate, internal assurance reviews or independent testing may examine:

• KYC procedures
• Transaction monitoring
• Sanctions screening
• Fraud controls
• Suspicious-activity escalation
• Recordkeeping
• Staff training
• Compliance oversight
• Risk assessments
• Regulatory reporting processes
• Tax-reporting processes
• Remediation of identified deficiencies

Material deficiencies will be documented and addressed through appropriate corrective actions.

Customers are responsible for providing accurate and complete information when requested.

Customers must not:

• Provide false identity information
• Submit altered or fraudulent documents
• Misrepresent the source of funds
• Misrepresent tax residency
• Use another person’s account without authorisation
• Attempt to circumvent transaction monitoring
• Use Asset Flow for unlawful activity
• Attempt to evade sanctions
• Attempt to avoid applicable regulatory requirements
• Provide misleading information during compliance reviews

Failure to provide required information may result in restricted, delayed or suspended services.

Asset Flow may determine whether a particular product, fiat currency, payment method or cryptocurrency service is available to customers in a particular jurisdiction.

Fiat services and any associated banking or payment services remain restricted-access services even where a currency or payment method is generally referenced in this policy. They are not automatically available to every registered user.

Services may be unavailable or restricted because of:

• Local laws or regulations
• Regulatory requirements
• Sanctions
• Payment-provider restrictions
• Banking-partner requirements
• Internal risk controls
• Customer eligibility
• Affiliate Investor qualification
• Active Group Investor status/account
• Geographic limitations
• Compliance considerations
• Technical availability

The availability of GBP, USD, CAD, AUD or EUR does not constitute a representation that every service associated with that currency is available in every jurisdiction, or that every registered user may access those services.

Asset Flow may modify, suspend or discontinue services where necessary to comply with applicable requirements or manage operational and regulatory risk.

Financial-services, cryptoasset, tax, AML/CTF and digital-asset regulation continues to develop internationally.

Asset Flow may update its compliance framework when:

• Laws change
• Regulations change
• Regulatory guidance changes
• Tax-reporting requirements change
• New financial-crime risks emerge
• New products or services are introduced
• Existing products or services are materially changed
• Payment or banking partners introduce new requirements

Customers may therefore be required to provide additional information or complete additional verification from time to time.

Asset Flow is committed to maintaining a risk-based compliance framework designed to protect customers, the platform and the wider financial system from misuse.

We will continue to monitor developments relating to:

• Cryptocurrency and digital-asset regulation
• Fiat financial services
• AML/CTF requirements
• Sanctions
• Fraud and financial crime
• Tax transparency
• Cryptoasset reporting
• Data protection
• Cross-border financial services
• Regulatory expectations

Asset Flow will update its policies, procedures and controls where appropriate to reflect material changes in applicable requirements and the services provided.

Customers should ensure that the information they provide to Asset Flow remains accurate and current and should independently confirm their own legal and tax obligations with the relevant authorities or qualified professional advisers.