AML Policy

Our Money Laundering And‍Terrorist Finance Prevention Policy

NjordX Finance OÜ maintains a policy of actively preventing and prohibiting money laundering and any activity that facilitates it and/or the funding of terrorist or criminal activities. Our AML and CTF policies and procedures are designed and intended in order to ensure compliance with all relevant and applicable regulations.

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Our Due Diligence Program

With all prospective customers, we take every effort to verify identities through the appropriate background checks. In the event that we do not have sufficient material to verify your identity or if there is any suspicious activity detected on your account, we reserve the right to restrict or outright deny access to your account and report the activity that we suspect to be fraudulent.

We implement reasonable measures to detect the use of our platform, website and services by sanctioned entities and, in the event that this activity is detected, it will be reported to the financial intelligence unit.

In the event that a person categorized as high-risk (as defined by the Financial Action Task Force) attempts to use our platform, we reserve the right to request additional pieces of identification as part of our enhanced due diligence regime. These additional measures help prevent access to our platform by those under sanction or attempting to use our platform with malicious intent.

This list of persons includes:

• Politically Exposed Persons, the families thereof or known associates and any individuals considered to reside in high-risk countries. This is a periodically updated list by the Financial Action Task Force.

Our Enhanced Due Diligence Program can be applied to any individuals that can be considered high risk as a result of our findings throughout the onboarding process. We use these terms in reference to the definitions stated by EU Directive 2015/849.

In the event that we deem it to be appropriate, we reserve the right to deny access to our platform or services without informing you of why the action was taken. The use of our services, platform or website is always at the discretion of NjordX Finance.

When an account is made on our Website, you acknowledge and consent to the following points:

• The information provided for the purposes of opening and operating an account is true and complete;

• The service is not to be used for any illegal purposes.

In using our service and website, you acknowledge and consent to the fact that we may forward your information, including your business details, account activity, posted transactions and more to any regulatory bodies and agencies in the following cases:

• We are required to do so by law or regulation; or

• We believe that the disclosure of such information helps prevent illegal activity including, but not limited to, fraud or money laundering.

Your compliance with these terms is implied when submitting any information to us. Therefore, it is highly recommended that you carefully read through these terms prior to opening an account with us. Any information that we collect for the purposes of rendering our services or opening an account will be handled in accordance with both our Privacy and Data Collection Policy.

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Disclosure of Source of Funds

The source of any funds used for the purposes of our services must be disclosed. Examples of this evidence include, for example, financial records of the registered business in question and in the name of the company.

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Virtual Asset Anonymising Services

We do not accept any form of funds that are transferred through or via coin mixing services. NjordX Finance reserves the right to deny our services to clients that intend to conduct transfers from high-risk exchanges that we believe to be engaged or affiliated with illegal activity.

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Suspicious Activity Monitoring

NjordX Finance monitors and examines transactions for unusual patterns or red flags that are congruent with the risk factors of our business. In the event that any such activity causes concern, or in the event that we are legally obligated to disclose the information to the relevant authorities, we will report such transactions. Further, we may submit an SAR for any such suspicious transactions that we believe may possibly violate any laws or regulations, even if not required by law to do so.

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Compliance with International Sanctions Regimes

We always take reasonable measures in order to ensure compliance with international financial sanctions as stipulated by the following bodies:

• The US Office of Financial Assets Control (USOC)

• The UK Office of Financial Sanctions Implementations (OFSI)

• The European Union (EU)

• The United Nations (UN)

During the onboarding of prospective clients, we take all reasonable precautions and measures in order to ensure that sanctioned individuals, companies or entities are denied access to our platform. Further, we also take measures to detect the use of platform by such sanctioned individuals. Any such attempts will be reported to the relevant authorities as soon as is reasonably possible.In the event that it is discovered that any entities using our platform are connected to sanctioned individuals or attempting to avoid sanctions, their accounts and associated services may be suspended.

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Transfer of Anti-Money Laundering Information to Law Enforcement Agencies and Personnel

In order to uphold their lawful duties, the FIU has the right to request information from NjordX Finance. If requested to do so, we are required to submit this information, including banking or business information within the indicated time limit.

As circumstances dictate, an individual request may result in the FIU forwarding the information to the compliance officer data registered in the FIU for the purposes of joint AML/CTF measures or the prevention of related criminal offenses.