AML, KYC and Sanctions Statement

This statement summarizes the anti-money-laundering (AML), counter-terrorist-financing, know-your-customer (KYC) and sanctions framework that we apply to products and services offered under the ORBITRA ONE™ brand. The legal obligations that apply depend on where and how each product is offered.

It is a summary. Our internal policies and procedures are more detailed and may be stricter than the description here.

We assess money-laundering, terrorist-financing, sanctions and fraud risk by customer type, jurisdiction, product, delivery channel and transaction pattern. The depth of due diligence and monitoring follows that assessment: higher-risk relationships receive enhanced checks, closer monitoring and senior approval.

The assessment is reviewed when products, markets, known typologies or laws change.

Customer due diligence takes place in the onboarding process for each product, not on this public website. The website never asks for identity documents, and a request for access submitted through it does not begin verification.

Depending on the product and the risk, onboarding may include:

• verifying the identity of individuals using reliable, independent sources;
• for institutions, verifying the entity, its ownership and control structure, its beneficial owners and the authority of the people acting for it;
• understanding the purpose and intended nature of the relationship and the expected activity;
• establishing the source of funds and, for higher-risk relationships, the source of wealth;
• screening for politically exposed persons, sanctions and relevant adverse media;
• confirming residence and eligibility for the products requested.

Enhanced due diligence applies where risk is higher, including for politically exposed persons and for relationships connected with higher-risk jurisdictions.

Verification outcomes are expressed through VaultID, the identity, eligibility and permission layer of ORBITRA ONE™. An account, institution or application can hold credentials that attest to specific attributes — such as verification level, jurisdiction or investor category — so that services can rely on them without receiving the underlying documents.

Credentials can be limited in scope and duration, and they can be updated, suspended or revoked when circumstances change or checks are refreshed. Regulated assets and markets can require particular credentials before granting access.

VaultID does not reduce the checks the law requires. Underlying verification records are protected as described in the product privacy notice and our privacy policy.

We screen customers, beneficial owners, authorized persons and, where relevant, counterparties and blockchain addresses against the sanctions lists that apply to us — at onboarding, whenever the lists change and on an ongoing basis. Blockchain analytics may be used to assess exposure to sanctioned or illicit sources.

We do not provide services to sanctioned persons or to anyone acting for them, and we do not facilitate activity involving comprehensively sanctioned jurisdictions. See jurisdictions and restricted persons.

Relationships are monitored throughout their life, and customer information is refreshed periodically and whenever risk indicators change.

Transaction monitoring looks for patterns associated with money laundering, terrorist financing, fraud and sanctions evasion. Market surveillance reviews order-book, RFQ and block activity for manipulation and abuse, such as spoofing, layering, wash trading, front-running and insider dealing.

Automated agents and strategies are subject to the same surveillance as manual trading, and their action receipts form part of the record under review.

We decline, or end, relationships with persons who:

• are sanctioned, are owned or controlled by sanctioned persons, or act on their behalf;
• reside in, or access products from, a restricted jurisdiction;
• do not provide the information needed to complete due diligence, or provide false or misleading information;
• use products for, or to conceal, money laundering, terrorist financing, fraud, sanctions evasion, market abuse or other unlawful activity;
• attempt to circumvent eligibility, sanctions or monitoring controls, including through false location data, nominees or undisclosed third parties.

We keep records of due diligence, transactions, screening results, alerts, investigations and reports for the periods required by applicable law, which can extend beyond the end of a relationship. Records are access-controlled and used only for lawful purposes. When a retention period ends, records are securely deleted.

To meet our legal obligations and manage risk, and where the law permits, we may:

• decline to open an account or to provide a product;
• request additional information or documents at any time;
• delay or refuse a transaction, deposit or withdrawal;
• restrict or freeze an account, a credential or assets we hold for you;
• end a relationship.

As required by law, we report suspicious activity to the competent authorities, respond to lawful requests and orders from regulators, law-enforcement agencies and courts, and comply with asset-freezing and sanctions-reporting obligations.

The law may prohibit us from explaining the reasons for a restriction or from telling you that a report has been made or a request received.

Provide complete and accurate information during onboarding and keep it current. Tell us promptly about changes in your residence, ownership, control or sanctions status. Do not use products on behalf of another person unless that arrangement has been disclosed to and approved by us.

Send questions about this statement, including due-diligence questionnaires from financial institutions and counterparties, to hello@orbitraone.com. The same address can be used to report suspected misuse of ORBITRA ONE™ products or schemes that misuse our name.