AML Policy

1. Purpose & Scope

Qenetex ("Platform"), operated by X Corp, maintains this Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy to prevent the use of our services for illicit purposes. This policy applies to all users, employees, and third parties interacting with the Platform.

X Corp is committed to complying with applicable AML/CTF regulations including the Bank Secrecy Act (BSA), USA PATRIOT Act, and Financial Action Task Force (FATF) recommendations.

2. Risk-Based Approach

The Platform employs a risk-based approach to AML compliance, assessing and mitigating risks associated with:

• Geographic risk — Transactions involving high-risk jurisdictions identified by FATF, OFAC, and EU sanctions lists
• Transaction risk — Unusual patterns, large deposits, rapid movement of funds, or structuring behavior
• Customer risk — Politically exposed persons (PEPs), sanctioned entities, and suspicious user behavior
• Product risk — Privacy coins, mixers, and high-anonymity transfer methods

3. Customer Due Diligence (CDD)

4. Transaction Monitoring

The Platform implements automated systems to detect and flag:

• Deposits from wallets associated with darknet markets, ransomware, or mixers
• Transactions involving OFAC-sanctioned addresses
• Structuring — multiple transactions designed to avoid detection thresholds
• Rapid deposit-and-withdrawal patterns inconsistent with trading activity
• Deposits from jurisdictions with elevated money laundering risk
• Anomalous behavior inconsistent with a user's established profile

5. Sanctions Compliance

The Platform screens all wallet addresses and user data against sanctions lists maintained by:

• U.S. Department of the Treasury — Office of Foreign Assets Control (OFAC)
• United Nations Security Council
• European Union consolidated sanctions list
• Financial Action Task Force (FATF) high-risk jurisdictions

Users from comprehensively sanctioned jurisdictions (including but not limited to North Korea, Iran, Syria, Cuba, and Crimea) are prohibited from using the Platform.

6. Suspicious Activity Reporting

When suspicious activity is identified, the compliance team conducts an internal investigation. If warranted, the Platform will:

• File a Suspicious Activity Report (SAR) with FinCEN or applicable authority
• Freeze the associated account pending investigation
• Cooperate with law enforcement requests as required by law
• Retain all relevant records for the mandated retention period

7. Record Keeping

The Platform retains all transaction records, CDD documentation, and SAR filings for a minimum of 5 years from the date of the transaction or account closure, in accordance with BSA requirements. Records include:

• Account registration data and modification history
• Deposit and withdrawal records with blockchain transaction hashes
• IP addresses and login/session history
• Internal investigation notes and compliance decisions
• Communications with law enforcement

8. Compliance Officer

X Corp designates a Compliance Officer responsible for overseeing the implementation and enforcement of this AML/CTF policy. The Compliance Officer ensures staff training, policy updates, and regulatory reporting obligations are met.

9. Employee Training

All employees with access to user data or transaction systems receive AML/CTF training upon onboarding and annual refresher courses covering:

• Recognition of suspicious activity patterns
• Escalation and reporting procedures
• Regulatory obligations and updates
• Blockchain-specific risks (mixers, privacy coins, cross-chain bridges)

10. Policy Updates

This AML policy is reviewed and updated at least annually, or more frequently in response to regulatory changes, new risk assessments, or enforcement actions. Material changes are communicated to all relevant stakeholders.