Anti-Money Laundering (AML) & Counter-Terrorism Financing (CTF) Policy

1 Introduction

Money laundering is the process of concealing the origins of illegally obtained money. Terrorist financing involves providing financial support to terrorist activities or organisations. Both are serious criminal offences that HyperX actively works to prevent.

This policy applies to all HyperX employees, contractors, agents, and users of the Platform. Our compliance framework is built on four pillars: prevention, detection, reporting, and cooperation with regulatory authorities.

2 Scope & Regulatory Framework

This policy applies to all services offered through the HyperX Platform, including cryptocurrency exchanges, fiat payouts, browser payments, DApp integrations, and the P2P programme.

HyperX operates in compliance with the following regulatory frameworks where applicable:

• Nigeria: Central Bank of Nigeria (CBN) AML/CFT Regulations; Nigerian Financial Intelligence Unit (NFIU) guidelines
• Kenya: Proceeds of Crime and Anti-Money Laundering Act (POCAMLA); Financial Reporting Centre (FRC) requirements
• South Africa: Financial Intelligence Centre Act (FICA); Financial Intelligence Centre (FIC) directives
• Ghana: Anti-Money Laundering Act 2008 (Act 749); Anti-Money Laundering Authority (AMLA) regulations
• International: FATF (Financial Action Task Force) Recommendations; EU 6th Anti-Money Laundering Directive where applicable

3 Risk-Based Approach

HyperX employs a risk-based approach to AML compliance, recognising that different customers, products, and transaction types carry different levels of risk. We allocate compliance resources proportionally to these risk levels.

3.1 Risk Categories

High-risk customers are subject to Enhanced Due Diligence (EDD) and increased transaction monitoring. HyperX may refuse to onboard or transact with customers assessed as excessively high risk.

4 Know Your Customer (KYC)

All users must complete KYC verification before accessing full platform functionality. KYC is conducted in tiers based on transaction volume and risk profile:

KYC verification is conducted in partnership with regulated identity verification providers. Documents accepted include national identity cards, international passports, and driver's licences.

5 Customer Due Diligence (CDD)

5.1 Standard CDD

Applied to all customers. Includes identity verification, address verification, and assessment of the purpose and intended nature of the business relationship.

5.2 Enhanced Due Diligence (EDD)

Applied to high-risk customers including Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, and those with unusual transaction patterns. EDD involves:

• Additional documentation (source of wealth, source of funds)
• Senior management approval before account activation
• Ongoing enhanced transaction monitoring
• More frequent periodic reviews

5.3 Simplified Due Diligence (SDD)

May be applied to demonstrably low-risk customers and transactions where regulations permit, such as small-value transactions with verified retail customers.

5.4 Ongoing Due Diligence

Customer profiles are reviewed periodically and whenever material changes in behaviour or risk are detected. Users may be required to re-submit KYC documentation if their information becomes outdated or a higher risk is identified.

6 Transaction Monitoring

HyperX employs automated and manual transaction monitoring systems to detect suspicious or unusual activity. Our monitoring systems flag transactions that exhibit the following characteristics:

• Structuring — breaking large amounts into smaller transactions to avoid reporting thresholds
• Rapid movement — funds deposited and immediately withdrawn without clear economic purpose
• Inconsistency — transaction patterns inconsistent with the customer's stated profile or income
• High-risk geography — transactions involving wallets or beneficiaries in sanctioned or high-risk jurisdictions
• Layering — multiple rapid transfers between wallets with no apparent purpose
• Unusual volumes — transaction volumes that significantly exceed historical norms for the customer

Flagged transactions are reviewed by our compliance team. We reserve the right to delay or freeze transactions pending investigation without prior notice to the user where legally required.

7 Sanctions Screening

All users, transactions, and counterparties are screened against international and local sanctions lists in real time, including:

• OFAC (Office of Foreign Assets Control) SDN List
• United Nations Security Council Consolidated List
• European Union Consolidated Sanctions List
• UK HM Treasury Financial Sanctions List
• National sanctions lists of Nigeria, Kenya, South Africa, and Ghana

Any match against a sanctions list will result in immediate account suspension, freezing of funds, and mandatory reporting to relevant authorities. Users have the right to appeal a false positive match through our compliance team.

8 Suspicious Activity Reporting (SAR)

Where HyperX identifies activity that gives rise to suspicion of money laundering or terrorist financing, we are legally obligated to file a Suspicious Activity Report (SAR) with the relevant Financial Intelligence Unit (FIU) in the applicable jurisdiction.

Our SAR process:

1. Compliance team identifies and documents the suspicious activity
2. Internal escalation to the Money Laundering Reporting Officer (MLRO)
3. MLRO assesses whether to file an SAR based on available evidence
4. SAR is filed with the appropriate authority within the legally required timeframe
5. Account and transaction restrictions applied as necessary pending investigation

9 Politically Exposed Persons (PEPs)

A Politically Exposed Person (PEP) is an individual who holds or has held a prominent public function, or is a close associate or family member of such a person. PEPs pose a higher risk of involvement in bribery and corruption.

HyperX screens all users against PEP databases upon registration and on an ongoing basis. PEPs are subject to:

• Enhanced Due Diligence (EDD) at onboarding
• Senior management approval before account activation
• Source of wealth and source of funds verification
• Ongoing enhanced transaction monitoring throughout the relationship
• Annual reviews of their PEP status and associated risk

HyperX does not automatically refuse service to PEPs, but we apply heightened scrutiny and may decline to onboard where the risk is assessed as unacceptably high.

10 Record Keeping

HyperX maintains comprehensive records of all customer information, transactions, and compliance activities in accordance with regulatory requirements:

All records are stored securely and are accessible to regulatory authorities upon lawful request. Records are protected against unauthorised access, alteration, or destruction.

11 Staff Training & Awareness

All HyperX employees involved in customer-facing, compliance, or operational roles receive mandatory AML/CTF training covering:

• Recognition of money laundering red flags and suspicious activity indicators
• KYC and CDD procedures and documentation requirements
• Sanctions screening procedures and escalation protocols
• SAR filing procedures and tipping-off prohibitions
• Applicable laws and regulations in all operating jurisdictions
• Data protection requirements in relation to AML records

Training is conducted at onboarding and refreshed annually or whenever significant regulatory changes occur. Training completion is documented and retained.

12 Prohibited Countries & Jurisdictions

HyperX does not provide services to users located in, or transactions involving, the following categories of jurisdictions:

• Countries subject to comprehensive OFAC, UN, or EU sanctions (e.g. Iran, North Korea, Cuba, Syria, Russia — certain sectors)
• FATF-identified high-risk jurisdictions subject to increased monitoring
• Jurisdictions where cryptocurrency services are explicitly prohibited by law

This list is subject to change in line with updates to international sanctions regimes and FATF guidance. HyperX monitors these lists continuously and updates its controls accordingly.

Users who attempt to access our services from prohibited jurisdictions using VPNs or other circumvention tools will be permanently banned and reported to relevant authorities.

13 Compliance Contact

For AML/CTF enquiries, compliance concerns, or to report suspicious activity involving HyperX, please contact our compliance team:

HyperX cooperates fully with law enforcement and regulatory authorities. Valid legal process (court orders, regulatory requests) should be directed to contact@hyperx.llc.