AML Policies

Anti-Money Laundering and Counter-Terrorism Financing policies for Neostox AI platform compliance and security.

AML Program Overview

Neostox AI maintains a comprehensive Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) program designed to detect and prevent illicit financial activities on our AI-powered cryptocurrency options trading platform.

Our AML program complies with applicable international standards, regulatory requirements, and best practices in the cryptocurrency and financial services industry.

We are committed to preventing our platform from being used for money laundering, terrorist financing, sanctions evasion, or other illegal activities while maintaining the privacy and security of legitimate users.

Know Your Customer (KYC)

All users must complete our comprehensive KYC verification process before accessing our trading platform:

Identity Verification

Government-issued photo identification, proof of address, and biometric verification to confirm user identity and prevent identity theft.

Enhanced Due Diligence

Additional verification for high-risk customers, politically exposed persons (PEPs), and users from high-risk jurisdictions.

Source of Funds

Documentation and verification of the legitimate source of funds used for cryptocurrency trading activities.

Ongoing Monitoring

Continuous monitoring of user activities and periodic review of customer information to detect suspicious patterns or changes.

KYC Requirements by Tier

Verification TierRequirementsTrading Limits
BasicEmail + PhoneLimited access
StandardID + Address verificationStandard limits
EnhancedFull EDD + Source of fundsHigher limits

Transaction Monitoring

We employ advanced monitoring systems to detect and report suspicious activities:

AI-Powered Detection

Machine learning algorithms analyze transaction patterns, user behavior, and market data to identify potentially suspicious activities in real-time.

Risk Scoring Models

Automated risk assessment systems assign risk scores to transactions and users based on multiple factors including geography, transaction size, and historical patterns.

Pattern Analysis

Detection of unusual trading patterns, structuring attempts, rapid movement of funds, and other indicators of potential money laundering.

Real-Time Alerts

Immediate alerts for high-risk transactions, enabling prompt investigation and potential blocking of suspicious activities.

Blockchain Analysis

Integration with blockchain analytics tools to trace cryptocurrency flows and identify connections to known illicit addresses.

Regulatory Reporting

Automated generation of suspicious activity reports (SARs) and other regulatory filings as required by applicable jurisdictions.

Sanctions Screening

Neostox AI maintains comprehensive sanctions screening procedures to comply with international sanctions regimes:

Sanctions Lists Monitored

  • • United Nations Security Council Consolidated List
  • • U.S. Office of Foreign Assets Control (OFAC) sanctions lists
  • • European Union sanctions regimes
  • • UK HM Treasury sanctions list
  • • Additional country-specific sanctions programs
  • • Politically Exposed Persons (PEP) databases

Screening Procedures

  • • Real-time screening during account registration
  • • Ongoing monitoring of existing customer databases
  • • Transaction-level screening for sanctions violations
  • • Daily updates from sanctions list providers
  • • Manual review of potential matches
  • • Escalation procedures for confirmed violations

Compliance Actions

  • • Immediate account blocking for confirmed matches
  • • Asset freezing in accordance with sanctions requirements
  • • Reporting to relevant regulatory authorities
  • • Documentation of compliance actions taken
  • • Legal review of complex sanctions matters
  • • Cooperation with law enforcement investigations

Suspicious Activity Reporting

When suspicious activities are detected, we follow established reporting procedures:

Report TypeTrigger CriteriaTimelineRecipients
Suspicious Activity Report (SAR)Unusual patterns, large transactions, suspected MLWithin 30 daysFinancial Intelligence Units
Currency Transaction Report (CTR)Large cash equivalent transactionsWithin 15 daysRegulatory authorities
OFAC Violation ReportSanctions screening hitsImmediatelyOFAC, law enforcement
Cyber Crime ReportHacking, fraud, cyber attacksWithin 24 hoursCyber crime units

Reporting Standards

All suspicious activity reports are prepared in accordance with applicable regulatory requirements and include detailed transaction information, customer data, and analysis of suspicious patterns. We maintain strict confidentiality of reported activities and cooperate fully with regulatory investigations.

Record Keeping Requirements

Neostox AI maintains comprehensive records in accordance with AML regulations:

Required Records

Customer Identification5 Years
Transaction Records5 Years
Suspicious Activity Reports5 Years
Training Records3 Years

Data Protection

Encrypted storage of sensitive records
Access controls and audit trails
Secure data transmission protocols
Regular backup and recovery procedures
Compliance with data protection laws
Secure destruction of expired records

Training & Awareness

All Neostox AI personnel receive comprehensive AML training and ongoing education:

Initial Training

  • • AML/CTF fundamentals
  • • Regulatory requirements
  • • Company policies and procedures
  • • Red flag identification
  • • Reporting obligations

Ongoing Education

  • • Annual refresher training
  • • Updates on regulatory changes
  • • New threat awareness
  • • Case study reviews
  • • Best practice sharing

Specialized Training

  • • Role-specific training programs
  • • Advanced detection techniques
  • • Cryptocurrency-specific risks
  • • Investigation procedures
  • • Customer interaction protocols

Training Compliance

All employees must complete mandatory AML training within 30 days of hire and annually thereafter. Training completion is tracked and documented, and failure to complete required training may result in restricted access to systems or disciplinary action.

Risk Assessment Framework

We maintain a comprehensive risk assessment framework to identify and mitigate ML/TF risks:

Geographic Risk

Assessment of money laundering and terrorist financing risks associated with different countries and jurisdictions.

Key Risk Factors:

FATF ratingsSanctions programsCorruption indicesRegulatory frameworks

Customer Risk

Evaluation of individual customer risk profiles based on various demographic and behavioral factors.

Key Risk Factors:

PEP statusOccupationTransaction patternsSource of funds

Product Risk

Analysis of inherent risks associated with different cryptocurrency products and services offered.

Key Risk Factors:

Privacy coinsMixing servicesCross-border transfersHigh-value transactions

Channel Risk

Assessment of risks related to different delivery channels and transaction methods used by customers.

Key Risk Factors:

Online platformsMobile appsAPI accessThird-party integrations

Transaction Risk

Real-time evaluation of individual transaction risks based on multiple dynamic factors.

Key Risk Factors:

Transaction sizeFrequencyVelocityCounterparties

Emerging Risks

Continuous monitoring and assessment of new and evolving money laundering threats.

Key Risk Factors:

DeFi protocolsNFT marketsCross-chain bridgesAI-generated fraud

Risk Assessment Updates

Our risk assessment framework is reviewed and updated annually or when significant changes occur in our business model, regulatory environment, or threat landscape. Regular risk assessments ensure our AML controls remain effective and proportionate to identified risks.

AML Governance & Oversight

Strong governance and oversight ensure the effectiveness of our AML program:

AML Officer Responsibilities

  • • Oversee day-to-day AML compliance operations
  • • Monitor suspicious activity detection systems
  • • Review and file suspicious activity reports
  • • Coordinate with law enforcement and regulators
  • • Maintain AML policies and procedures
  • • Conduct regular staff training programs

Board Oversight

  • • Quarterly AML program reviews
  • • Annual risk assessment approvals
  • • Policy and procedure ratification
  • • Resource allocation decisions
  • • Regulatory relationship management
  • • Independent audit oversight

Three Lines of Defense

First Line:
  • • Business operations
  • • Customer onboarding
  • • Transaction monitoring
  • • Initial screening
Second Line:
  • • AML compliance function
  • • Risk management
  • • Policy oversight
  • • Independent review
Third Line:
  • • Internal audit
  • • Independent testing
  • • Effectiveness assessment
  • • Board reporting

AML Contact Information

For AML-related inquiries, compliance matters, or suspicious activity reporting:

AML Compliance Team

Contact us through our support channels for AML-related inquiries
Suspicious Activity Hotline: 24/7
Response time: Within 24 hours

Chief Compliance Officer

Contact us through our support channels for compliance matters
AML program oversight
Regulatory liaison

Emergency Reporting

For urgent suspicious activity reporting or potential sanctions violations, contact our 24/7 emergency hotline immediately. Do not delay reporting time-sensitive compliance matters.

Last Updated

These AML Policies were last updated on September 6, 2025

Policies are reviewed annually and updated as needed to reflect regulatory changes.

AML Compliance Questions?

Our compliance team is available 24/7 to assist with AML matters, suspicious activity reporting, and regulatory compliance questions.