Anti-Money Laundering Policy

Introduction

Tradevent Ltd is committed to combating money laundering, terrorist financing, and all forms of financial crime. This policy outlines our obligations and internal procedures under applicable UK and international AML regulations, including:

• The Proceeds of Crime Act 2002 (POCA)
• The Terrorism Act 2000
• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
• Germany's Money Laundering Act (Geldwäschegesetz — GwG), where applicable to cross-border operations
• FATF (Financial Action Task Force) Recommendations

Compliance with these obligations is not optional. Every employee and contractor of Tradevent Ltd, and every customer who uses the platform, is subject to this policy. Failure to comply may result in account termination, reporting to authorities, and legal consequences under applicable law.

Our nominated Money Laundering Reporting Officer (MLRO) is responsible for overseeing all AML procedures, receiving internal reports, and making disclosures to the National Crime Agency (NCA) where required.

Know Your Customer (KYC)

All customers must complete identity verification before their account is activated and before any deposit is accepted. This is a mandatory, non-negotiable requirement. KYC is completed in the following steps:

KYC data is verified by our regulated third-party identity verification provider. All KYC documents are encrypted at rest and access-controlled. KYC verification results are retained for a minimum of 7 years following account closure.

Transaction Monitoring

All transactions on the platform are subject to automated and manual monitoring. Our monitoring programme is designed to detect:

• Unusually large deposits relative to the account's stated investment purpose
• Rapid or repeated withdrawal requests following large deposits
• Patterns of structuring — splitting large sums into smaller deposits to avoid thresholds
• Use of multiple wallet addresses with no clear rationale
• Transactions originating from or directed to high-risk jurisdictions
• Wallet addresses flagged by blockchain analytics as associated with known criminal activity

Blockchain analytics tools are used to screen all incoming and outgoing wallet addresses for connections to darknet markets, ransomware, theft, sanctions, or other illicit activity. Transactions from flagged addresses will be rejected or quarantined for review.

The Company reserves the right to freeze accounts pending investigation without prior notice where suspicious activity is detected. Affected customers will be notified of the freeze and provided with a contact point, subject to any legal obligations to withhold such notification.

Prohibited Transactions

The following transactions and account behaviours are strictly prohibited on the Tradevent platform:

Funds from prohibited transactions will not be credited. Where such transactions are discovered after crediting, funds will be frozen and the matter referred to the MLRO for assessment and potential NCA disclosure. The platform will return funds only to the verified originating wallet address; no alternative destinations are permitted.

Suspicious Activity Reporting

The Company's nominated MLRO is responsible for receiving internal suspicion reports from staff, evaluating them, and making Suspicious Activity Reports (SARs) to the National Crime Agency (NCA) via the NCA's Online Disclosure Service where required by law.

Staff obligations under this policy include:

• Reporting any suspicion of money laundering or terrorist financing to the MLRO immediately upon becoming aware of it
• Not tipping off customers or third parties that a report has been made or an investigation is underway
• Cooperating fully with any investigation by the MLRO, the NCA, or other competent authorities
• Completing mandatory AML training, which is conducted on an annual basis and updated whenever regulatory requirements change

The tipping off prohibition is a criminal offence under the Proceeds of Crime Act 2002. Staff and customers are reminded that disclosing the existence of a SAR or live investigation to any person suspected of involvement is unlawful.

Record Keeping

In accordance with the Money Laundering Regulations 2017, the Company maintains comprehensive records for a minimum of 7 years from the date of the transaction or the end of the business relationship, whichever is later. Records retained include:

• All KYC documentation and identity verification results
• Transaction records including deposit amounts, wallet addresses, timestamps, and transaction IDs
• AML screening results and blockchain analytics reports
• Internal suspicion reports and MLRO assessment records
• SARs filed with the NCA (maintained separately and subject to strict access controls)
• Staff AML training records and certification

All records are stored in encrypted form with access restricted to authorised personnel on a strict need-to-know basis. Records are available for production to competent authorities upon lawful request without undue delay.