Anti-Money Laundering Policy

At FillyX, we are committed to maintaining the highest standards of integrity and compliance. This Anti-Money Laundering (AML) Policy outlines our approach to detecting and preventing any activity related to money laundering, terrorist financing, or other financial crimes.

1. Purpose

This AML Policy is designed to:

• Prevent the use of FillyX's platform for money laundering or terrorist financing.
• Ensure compliance with all applicable AML laws and regulations.
• Protect our users and our platform from illicit activities.

2. What Is Money Laundering?

Money laundering refers to disguising the origins of illicit funds by routing them through multiple financial operations to make them appear legitimate.

3. Our Commitment

FillyX maintains a risk-based approach to AML compliance and implements robust controls to:

• Identify and verify the identity of our customers (KYC).
• Monitor transactions for suspicious activity.
• Report suspicious transactions to relevant authorities.

4. Customer Due Diligence (CDD) & KYC

Before granting access to our services, we perform identity verification processes including:

• Verifying the name of the customer.
• Verifying the Government-issued ID.
• Verifying the Proof of Address.
• Verifying the Source of funds (where applicable).

We also conduct Enhanced Due Diligence (EDD) for high-risk customers, such as politically exposed persons (PEPs) or users from high-risk jurisdictions.

5. Ongoing Monitoring

FillyX uses automated tools and manual review processes to continuously monitor user activities and transactions. Any behavior that raises red flags, such as unusual transaction patterns or sudden large deposits, may lead to further investigation.

6. Reporting Suspicious Activity

In compliance with global AML standards, FillyX is obligated to:

• Cooperate fully with law enforcement agencies upon legitimate request.
• Maintain the confidentiality of all reports and investigations.

7. Staff Training & Awareness

All FillyX employees undergo regular AML training to:

• Stay updated with evolving AML laws and regulations.
• Understand how to identify and report suspicious activity.
• Promote a culture of compliance within the organization.

8. Record Keeping

We retain all relevant documentation (KYC data, transaction records, SARs) for a minimum of 5 years or as required by law.

9. Policy Updates

This AML Policy is reviewed periodically and updated to reflect changes in legal, regulatory, or operational requirements.