Compliance

Anti-Money Laundering, Counter-Terrorist Financing & Counter-Proliferation Financing Policy

Finlazo LtdEffective: September 2026

Finlazo maintains a risk-based framework intended to prevent and detect money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud and other financial-crime risks.

The framework operates alongside applicable laws and regulatory requirements in the jurisdictions where Finlazo operates. Where applicable local law imposes stricter requirements, those requirements prevail.

Publication of this policy does not itself represent that Finlazo holds a licence, registration or authorisation in a particular jurisdiction. Regulatory permissions depend on the relevant product, activity and jurisdiction.

01

Purpose

Finlazo is committed to protecting its payment and virtual-asset infrastructure from misuse. This framework supports appropriate governance, customer due diligence, sanctions controls, transaction monitoring, reporting, record keeping, training and assurance.

02

Scope

The framework applies to relevant Finlazo personnel, customers, beneficial owners, controlling persons and authorised representatives, as well as business customers, merchants and institutional users. It covers payments, virtual assets, wallets, transfers, conversion, settlement, on-ramp and off-ramp services, and relevant counterparties, providers, payment rails and blockchain addresses.

03

Governance and accountability

The Board and senior management oversee an effective financial-crime compliance framework, appropriate resources and a culture of compliance. The Compliance function and MLRO or equivalent senior compliance officer oversee the framework, investigations, regulatory reporting and compliance records.

04

Risk-based approach

Controls are proportionate to identified risks and calibrated to the nature, scale and complexity of the relevant activity. Finlazo considers customer, geographic, product and service, transaction, delivery-channel and counterparty or provider risk.

05

Customer acceptance

Finlazo may refuse, restrict or terminate a relationship where the relevant risks cannot be appropriately mitigated, required information is not provided, or doing so is required by applicable law or sanctions obligations.

06

Customer identification and verification

Finlazo applies KYC and KYB measures where relevant. These may include verifying identity, business details, beneficial ownership, control, authorised representatives and the purpose and expected nature of the relationship. Additional information may be requested where risk requires it.

07

Enhanced due diligence

Higher-risk relationships or activity may require additional verification, information about source of funds or source of wealth, enhanced monitoring and appropriate approval before or during the relationship.

08

Politically exposed persons

Finlazo applies a risk-based approach to politically exposed persons, their relevant family members and close associates where applicable law requires it. Additional controls may apply based on the circumstances and level of risk.

09

Sanctions

Finlazo maintains screening and controls intended to prevent prohibited dealings with sanctioned persons, entities, jurisdictions, wallets or transactions where applicable. Activity may be restricted or declined when required by applicable sanctions obligations.

10

Transaction monitoring

Finlazo applies risk-based monitoring to identify unusual, suspicious or potentially illicit activity across fiat and virtual-asset transactions. Monitoring is proportionate to the risks presented by the customer, service and activity.

11

Blockchain and virtual-asset controls

Where appropriate, Finlazo may use blockchain analytics, address screening and transaction tracing to understand exposure and support risk assessment. Blockchain exposure by itself does not automatically establish illicit activity; context and the overall risk picture are considered.

12

Travel Rule

Where applicable law requires originator and beneficiary information, Finlazo will collect, transmit, validate and retain the required information in accordance with applicable requirements.

13

Suspicious activity

Suspected financial crime is escalated to the Compliance function and reported to competent authorities where required. Finlazo protects the confidentiality of compliance information subject to applicable law.

14

Source of funds and source of wealth

Depending on risk, transaction characteristics or applicable law, Finlazo may request information and supporting evidence about the source of funds or source of wealth.

15

Record keeping

Finlazo maintains relevant compliance records, including appropriate customer and transaction information, for the periods required by applicable law.

16

Data protection and confidentiality

AML, CFT, CPF, sanctions and fraud controls operate alongside applicable privacy and data-protection obligations. Information is handled with appropriate confidentiality and lawful safeguards.

17

Staff training

Relevant personnel receive training appropriate to their responsibilities, including AML, CFT, CPF, sanctions, fraud and related financial-crime compliance risks.

18

Third-party and counterparty risk

Finlazo applies risk-based due diligence and oversight to relevant banks, payment service providers, virtual-asset service providers, custodians, liquidity providers and other material service providers.

19

New products and markets

Material new products, technologies, payment rails and jurisdictions are subject to appropriate financial-crime risk assessment before or as part of their introduction.

20

Fraud and financial crime

Finlazo considers risks including identity fraud, account takeover, stolen funds, payment fraud and social engineering, alongside money laundering, terrorist financing, proliferation financing and sanctions evasion risks.

21

Regulatory cooperation

Finlazo cooperates with competent authorities and responds to lawful requests, subject to applicable legal and confidentiality requirements.

22

Policy review

The policy framework is reviewed at least annually and sooner where material changes in the business, risk environment, applicable requirements or operating jurisdictions warrant review.

Framework summary

Key compliance principles

  • Know the customer
  • Understand purpose and expected activity
  • Identify ultimate ownership and control
  • Understand source of funds or wealth where required
  • Screen against applicable sanctions requirements
  • Monitor transactions and investigate meaningful anomalies
  • Escalate suspicious activity appropriately
  • Protect confidential compliance information
  • Maintain complete and retrievable records
  • Apply stronger controls where risk is higher

Compliance enquiries

Questions about this policy?

For compliance matters and regulatory enquiries, contact the Finlazo team.

compliance@finlazo.comView the compliance library