Effective Date: 11.11.2025

This Anti–Money Laundering and Counter-Terrorist Financing Policy (“Policy”) outlines the measures adopted by Veladur (“we,” “us,” “our”), owned and operated by Finstar Technologies Ltd., Marshall Islands, to prevent and detect money laundering, terrorist financing, fraud, and other financial crimes. By using the Veladur trading platform (“Platform”), users agree to comply with this Policy.

1. Purpose and Scope

This Policy establishes Veladur’s approach to AML/CTF compliance and applies to:

• All clients using the Platform
• All transactions, including deposits, withdrawals, and trading activity
• All employees, contractors, and internal support teams

Veladur follows internationally recognized AML/CTF requirements, including principles aligned with:
• EU AML directives
• FATF guidelines
• MiCA/MiFID-style conduct standards
• GDPR-aligned privacy practices
• UK-based financial crime prevention expectations

2. Prohibited Use of the Platform

Clients may not use the Platform for any unlawful activity, including:

• Money laundering or terrorist financing
• Sanctions evasion
• Fraud or identity theft
• Market abuse or manipulative trading
• Use of stolen financial instruments
• Use of tools intended to obscure transaction origins (e.g., mixers, tumblers)

Veladur reserves the right to block or restrict accounts that demonstrate suspicious behavior.

3. Eligibility & Restricted Jurisdictions

To comply with AML/CTF standards, Veladur does not onboard clients who:

• Are residents of the United States
• Are residents of jurisdictions subject to sanctions or international restrictions
• Appear on sanctions lists, including OFAC, UN, EU, UK HMT
• Intend to conceal the source or destination of funds

We reserve the right to reject applicants from high-risk jurisdictions or impose enhanced due diligence (“EDD”) where necessary.

4. Customer Due Diligence (CDD)

Veladur conducts Customer Due Diligence on all clients before account access is granted. Required information may include:

• Full legal name
• Date of birth
• Nationality
• Residential address
• Contact information
• Government-issued identification
• Selfie or biometric verification (if requested)
• Proof of address
• Proof of ownership for cryptocurrency wallets used for withdrawals

Veladur may request additional information at any time.

5. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is required when:

• A client is identified as a Politically Exposed Person (PEP)
• A client resides in a high-risk jurisdiction
• Transaction patterns suggest elevated financial crime risk
• There are inconsistencies in documentation
• There is any concern regarding source of funds/wealth

EDD measures may include:

• Source of funds/wealth verification
• Additional identity documents
• Verification of business or professional activities
• Monitoring of trading and funding behavior
• Delayed or restricted withdrawals until checks are complete

Veladur may refuse service or close accounts if EDD requirements are not met.

6. Ongoing Monitoring

Veladur maintains continuous monitoring of:

• Deposits and withdrawals
• Trading activity
• IP and device data
• Behavior patterns inconsistent with stated profile
• Sudden changes in risk indicators

Suspicious activity may result in:

• Temporary account restriction
• Reversal or delay of transactions
• Reporting to relevant authorities (where applicable)
• Account closure

Veladur is under no obligation to disclose details of internal investigations.

7. Source of Funds and Source of Wealth Verification

To ensure compliance, Veladur may require:

• Bank statements
• Payslips or income statements
• Tax returns
• Corporate documents (for business accounts)
• Evidence of savings or investments
• Proof of ownership for cryptocurrency assets or wallets

Clients must provide clear, legible documentation upon request.

8. Cryptocurrency Withdrawals

For crypto withdrawals, Veladur may require:

• Proof of wallet ownership
• Blockchain transaction history for risk assessment
• Additional documentation for large withdrawals or unusual patterns

Withdrawals may be delayed if:

• Ownership cannot be established
• Activity is deemed suspicious
• Additional verification is required

9. Sanctions Screening

Veladur screens clients and transactions against:

• OFAC sanctions lists
• UN Security Council sanctions
• EU consolidated lists
• UK HMT sanctions
• Other relevant international registers

Matches or potential matches may lead to account freezes and reporting obligations.

10. Reporting Obligations

Veladur may file internal or external reports where suspicious activity is identified.

• Clients are not notified when such reports are made
• Information may be provided to competent authorities if legally required
• Veladur follows “no tipping off” principles in compliance with AML laws

11. Record Keeping

Veladur retains AML/CTF-related records for the legally required period, including:

• Identity documents
• Transaction records
• Internal monitoring logs
• Communication records
• Risk assessments

Retention remains in force even if an account is closed.

12. Account Restrictions and Closure

Veladur may suspend, restrict, or close accounts if:

• Requested documents are not provided
• Suspicious activity is detected
• AML/CTF obligations require intervention
• False or misleading information is submitted
• The client breaches this Policy

Outstanding positions may be closed at Veladur’s discretion.

13. Client Responsibilities

Clients agree to:

• Provide accurate and truthful information
• Respond promptly to compliance requests
• Ensure deposits originate from legitimate sources
• Use only accounts/wallets in their own name
• Avoid any activity that may be considered suspicious or unlawful

Failure to comply may result in account action.

14. Training & Internal Controls

Veladur maintains internal AML/CTF controls, including:

• Employee training
• Suspicious activity detection
• Compliance oversight
• Periodic reviews of policy effectiveness

15. Amendments

Veladur may update this AML Policy at any time.
Continued use of the Platform constitutes acceptance of any revised version.

16. Contact Information

For compliance-related inquiries:
[email protected]