AML/KYC Policy

Effective Date: 11 June 2025

1. Purpose

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the procedures XS Trades Ltd. ("Company") follows to prevent the use of the PULSAR.INK platform (the "Platform") for money laundering, terrorist financing, or other illicit activities.

We are committed to complying with applicable AML/KYC laws and regulations in St. Vincent and the Grenadines and all jurisdictions where we operate.

2. KYC Verification Procedures

We implement a risk-based approach to customer identification:

2.1 Basic Verification

All users are identified through their Telegram account, which provides a unique user ID and associated profile information. This serves as the initial level of identification.

2.2 Enhanced Verification

We may require enhanced verification in the following circumstances:

Withdrawal requests exceeding certain thresholds
Unusual transaction patterns or volumes
Transactions flagged by our monitoring systems
Requests from high-risk jurisdictions
At our discretion based on risk assessment

Enhanced verification may include:

Government-issued photo identification (passport, national ID, driver's license)
Proof of address (utility bill, bank statement dated within 3 months)
Source of funds documentation
Selfie/video verification

3. Transaction Monitoring

We continuously monitor transactions on the Platform for suspicious activity, including:

Unusually large deposits or withdrawals
Rapid movement of funds (deposit followed by immediate withdrawal)
Transactions from or to sanctioned addresses
Patterns consistent with layering or structuring
Multiple accounts linked to the same person
Use of mixing services or privacy-focused tools

4. Suspicious Activity Reporting

If we identify or suspect money laundering, terrorist financing, or other criminal activity, we will:

File Suspicious Activity Reports (SARs) with the relevant Financial Intelligence Unit (FIU)
Freeze the associated account(s) pending investigation
Cooperate fully with law enforcement authorities
Not inform the user of the filing ("tipping off" prohibition)

5. Sanctions Compliance

We screen users and transactions against applicable sanctions lists, including but not limited to:

OFAC (Office of Foreign Assets Control) Specially Designated Nationals list
EU sanctions lists
UN Security Council sanctions
Local sanctions lists as applicable in St. Vincent and the Grenadines

6. Politically Exposed Persons (PEPs)

We apply enhanced due diligence measures for Politically Exposed Persons (PEPs) and their associates, including additional verification steps and ongoing monitoring.

7. Record Keeping

We maintain records of:

Customer identification data — for the duration of the business relationship plus a minimum of 5 years
Transaction records — for a minimum of 5 years from the date of the transaction
Suspicious activity reports — indefinitely or as required by law
KYC verification documents — for the duration of the business relationship plus a minimum of 5 years

8. Staff Training

All Company personnel involved in customer-facing roles, compliance, and transaction monitoring receive regular AML/KYC training covering identification of suspicious activity, reporting procedures, and regulatory updates.

9. Compliance Officer

We have designated a Compliance Officer responsible for overseeing the implementation of this policy, conducting risk assessments, and liaising with regulatory authorities.

10. Cooperation with Authorities

We cooperate fully with law enforcement agencies, regulatory bodies, and other competent authorities in the investigation and prevention of financial crimes. This includes providing information and documents upon lawful request.

11. Policy Updates

This policy is reviewed and updated regularly to ensure compliance with evolving regulations and best practices. Changes will be published on our website.

12. Contact

For AML/KYC-related inquiries, contact our Compliance team at contact@pulsar.ink.