AML & KYC Policy.

Plain-English summary: We are required by law to know who our clients are, where their money comes from, and to report suspicious activity. This document explains what that means for you in practice — what we ask for, when, and what happens if we can’t verify you.

01Our commitment

Xblu LTD is committed to preventing money laundering, terrorist financing, sanctions evasion and financial crime. We maintain a risk-based Anti-Money-Laundering (“AML”) and Counter-Terrorist-Financing (“CTF”) programme aligned with FATF recommendations and the AML laws applicable to our operations.

02Customer Due Diligence (CDD)

Before you can trade with real funds, we are required to verify your identity. Standard CDD includes:

• Identity: a valid government-issued photo ID (passport, national ID card or driving licence);
• Address: a recent (< 3 months) utility bill, bank statement or official letter showing your residential address;
• Liveness: a short video selfie to confirm the document belongs to you;
• Source of funds: where required, evidence of the origin of the funds you deposit (e.g. pay slips, sale contract, investment statements).

Most clients are verified within minutes. Complex cases may take up to 48 hours.

03Enhanced Due Diligence (EDD)

We apply EDD for higher-risk clients or transactions, including:

• Politically Exposed Persons (PEPs) and their close associates;
• Clients from higher-risk jurisdictions as identified by FATF;
• Unusually large or complex transactions inconsistent with the client’s profile;
• Any transaction with no apparent economic or lawful purpose.

EDD may include additional documentation, source-of-wealth questionnaires, and senior-management approval.

04Sanctions & PEP screening

All clients are screened, at onboarding and continuously thereafter, against:

• UN, EU, UK, OFAC and other applicable sanctions lists;
• Global PEP databases;
• Adverse media sources.

Matches result in account suspension pending investigation and, where required, reporting to the competent authority.

05Source of funds

We may ask you to evidence where your deposits originate. Acceptable sources include salary, business income, sale of property, inheritance, investment returns or savings. Funds derived from illegal activity will be frozen and reported.

Third-party deposits are not accepted — you may only fund your account from a payment method in your own name.

06Transaction monitoring

We monitor account activity in real time and on a delayed-batch basis using automated rules and analyst review. Indicators that may trigger review include:

• Rapid deposit followed by withdrawal without meaningful trading activity;
• Use of multiple payment methods or unrelated third-party accounts;
• Patterns consistent with structuring or layering;
• Trading activity inconsistent with the client’s declared profile.

07Reporting suspicious activity

Where we have reasonable grounds to suspect money laundering, terrorist financing or sanctions breaches, we are obliged to file a Suspicious Activity Report (“SAR”) with the competent Financial Intelligence Unit. By law, we may not inform the client that a SAR has been filed (“tipping off”).

08Record keeping

We retain identification, due-diligence and transaction records for a minimum of seven (7) years after the closure of your account, as required by applicable AML legislation.

09Training & governance

All XBlu staff complete mandatory AML/CTF training at onboarding and annually thereafter. Our AML programme is overseen by a designated Money Laundering Reporting Officer (MLRO) reporting directly to the board.

10Cooperation with authorities

We cooperate fully with law-enforcement and regulators upon receipt of valid legal requests. Where we are legally permitted to do so, we will notify you of any disclosure relating to your account.

11Contact

Questions about our AML/KYC programme can be sent to compliance@xblu.io.