Anti-Money Laundering Policy

1. Overview

NIXAFIRM Ltd is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. This policy sets out our approach to preventing the NIXAFIRM platform from being used to launder money or finance terrorism.

2. Legal Obligations

We operate under the following legal frameworks:

• UK Proceeds of Crime Act 2002 (POCA)
• Terrorism Act 2000 and Counter-Terrorism Act 2008
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
• Financial Action Task Force (FATF) Recommendations
• FCA Financial Crime Guide
• EU 5th and 6th Anti-Money Laundering Directives (as applicable post-Brexit)

3. Customer Due Diligence (CDD)

We apply a risk-based approach to customer due diligence:

3.1 Standard CDD (all customers)

• Government-issued photo identification (passport, national ID, driver's licence)
• Selfie with ID document
• Proof of address (utility bill, bank statement dated within 3 months)
• Date of birth and nationality verification

3.2 Enhanced Due Diligence (EDD)

We apply EDD for higher-risk customers including:

• Politically Exposed Persons (PEPs) and their associates
• Customers from high-risk jurisdictions (as classified by FATF)
• Customers with unusual transaction patterns
• Customers depositing or withdrawing amounts over $50,000
• Customers where source of funds is unclear

EDD may include source of funds documentation, source of wealth declaration, senior management approval, and enhanced ongoing monitoring.

4. Transaction Monitoring

We continuously monitor transactions for suspicious patterns including:

• Unusually large deposits or withdrawals not in line with customer profile
• Rapid movement of funds (deposit and immediate withdrawal)
• Transactions from or to sanctioned countries or individuals
• Multiple small transactions that appear to structure around reporting thresholds
• Deposits from third-party accounts
• Cryptocurrency transactions with high-risk exposure flags

5. Suspicious Activity Reporting

We are legally required to file Suspicious Activity Reports (SARs) with the National Crime Agency (NCA) when we suspect money laundering or terrorist financing. We are prohibited from "tipping off" customers that a SAR has been filed.

If we cannot complete required CDD, we will not provide services and may terminate accounts. We cooperate fully with law enforcement and regulatory authorities.

6. Record Keeping

We retain all customer identification documents and transaction records for a minimum of 5 years from the end of the business relationship, as required by the Money Laundering Regulations 2017.

7. Staff Training

All NIXAFIRM employees receive AML/CTF training upon joining and annually thereafter. Our Money Laundering Reporting Officer (MLRO) oversees compliance and is the designated contact for all AML matters.

8. Contact

For AML-related queries or to report concerns: compliance@nixafirm.com