Anti-Money Laundering & KYC Policy

Elysium Trade is committed to preventing money laundering, terrorist financing, and other financial crimes. This AML/KYC Policy establishes our procedures for customer identification, transaction monitoring, and regulatory reporting.

We operate under MISA License BFX2025124 and comply with the AML/CFT requirements of the Mwali International Services Authority.

Our AML/KYC procedures are designed in accordance with:

• MISA AML/CFT Regulations (Mwali, Comoros)
• FATF (Financial Action Task Force) Recommendations
• International standards for Virtual Asset Service Providers (VASPs)

We operate a tiered KYC system based on transaction volumes:

4.1 Standard CDD applies to all users and includes:

• Collection and verification of email address
• IP address and geolocation screening
• Sanctions list screening

4.2 Enhanced Due Diligence (EDD) is triggered by:

• Monthly transaction volumes exceeding Tier 1 limits
• Transactions from or to high-risk jurisdictions
• Unusual transaction patterns or volumes
• Withdrawal requests exceeding $5,000 USDT in a single transaction

4.3 Politically Exposed Persons (PEPs): Users identified as PEPs are subject to enhanced due diligence and may be required to provide additional documentation.

We do not accept customers from or conducting transactions with:

• United States of America and its territories
• Canada
• Japan
• Democratic People's Republic of Korea (North Korea)
• Iran
• Syria
• Countries on the FATF grey list or black list as of the effective date

We use geolocation and IP screening to detect and block access from restricted jurisdictions. Use of VPNs to circumvent jurisdiction restrictions is a violation of our Terms of Service.

We monitor transactions for the following suspicious indicators:

• Rapid deposit and withdrawal without trading activity (“pass-through”)
• Structuring of transactions to stay below reporting thresholds
• Multiple accounts controlled by the same individual
• Transactions from wallets flagged by blockchain analytics tools
• Unusual trading patterns inconsistent with the user's profile

Where we identify suspicious activity, we will:

1. Freeze the relevant account pending investigation
2. Preserve all related records
3. File a Suspicious Activity Report with MISA where required
4. Not inform (“tip off”) the account holder that an investigation is underway

We maintain the following records for a minimum of 5 years from the date of the transaction or account closure (whichever is later):

• All customer identification documents
• Transaction records (all deposits, withdrawals, trades)
• Suspicious Activity Reports
• Results of sanctions and PEP screenings

All users are screened against the following sanctions lists upon registration and on a periodic basis:

• UN Security Council Consolidated Sanctions List
• OFAC (U.S. Office of Foreign Assets Control) SDN List
• EU Consolidated Sanctions List
• UK HM Treasury Financial Sanctions List

Users matching sanctions lists will have their accounts immediately suspended and funds frozen pending regulatory review.

All personnel with access to user data or transaction systems receive training on:

• Recognition of money laundering typologies
• KYC verification procedures
• Suspicious activity identification and reporting obligations
• Data protection requirements

Elysium Trade has designated an AML Compliance Officer responsible for:

• Implementing and maintaining this Policy
• Reviewing and updating procedures as regulations change
• Handling SAR filings and regulatory correspondence

Contact: aml@elysiumtrade.cfd

This Policy is reviewed at least annually and updated as required by changes in applicable law, regulatory guidance, or business operations.