Anti-Money Laundering (AML) Policy

1. Purpose and Scope

Settlra Technologies Ltd ("Settlra") is committed to the highest standards of anti-money laundering (AML) and counter-terrorism financing (CTF) compliance. This policy outlines our program for detecting, preventing, and reporting activities that may constitute money laundering, terrorist financing, or other financial crimes.

This policy applies to all customers, transactions processed through the Settlra platform, and Settlra personnel involved in compliance activities.

2. Customer Due Diligence (CDD)

Settlra applies a risk-based approach to customer due diligence. All customers undergo identity verification prior to accessing the Services. The level of due diligence is proportionate to the assessed risk:

• Standard CDD: Applied to all customers. Includes business registration verification, email verification, and basic use-case assessment.
• Enhanced Due Diligence (EDD): Applied to high-volume customers, customers in higher-risk jurisdictions, and customers with complex ownership structures. Includes UBO verification, source of funds documentation, and periodic review.
• Simplified CDD: Not applied — all customers receive at minimum Standard CDD.

3. Sanctions Screening

All customers and transaction counterparties are screened against applicable sanctions lists at onboarding and on an ongoing basis. Sanctions lists screened include: OFAC SDN and Non-SDN lists, UN Security Council Consolidated List, EU Financial Sanctions Database, HM Treasury Office of Financial Sanctions Implementation (OFSI) list, and Politically Exposed Persons (PEP) databases.

Any positive match results in an immediate hold on the account or transaction, pending review by our compliance team. Confirmed matches are reported to the applicable authorities and the account is terminated.

4. Transaction Monitoring

Settlra operates an automated transaction monitoring system that screens all transactions in real time. The system applies rules-based and behavioral analytics to identify patterns including:

• Rapid succession of high-value transactions (velocity checks)
• Transactions just below reporting thresholds (structuring indicators)
• Unusual geographic patterns or recipient concentration
• Sudden changes in transaction volume or behavior
• On-chain analytics indicating high-risk USDC source wallets

5. Suspicious Activity Reporting

Where Settlra suspects that a transaction involves proceeds of crime or is connected to terrorist financing, we will file a Suspicious Activity Report (SAR) or equivalent report with the appropriate Financial Intelligence Unit (FIU) in accordance with applicable law. We are prohibited by law from disclosing to customers or third parties that a SAR has been or may be filed (tipping-off prohibition).

6. Record Keeping

Settlra maintains records of all customer due diligence documentation, transaction records, and suspicious activity reports for a minimum of 7 years from the date of the transaction or the end of the customer relationship, whichever is longer. Records are maintained in a form that can be provided to regulatory authorities within a reasonable time upon request.

7. Customer Obligations

By using the Services, customers agree to: (a) provide accurate KYC documentation and update it upon material change; (b) use the Services only for lawful purposes; (c) not use the Services to process payments on behalf of third parties without prior written consent; (d) cooperate with any compliance investigation or request for information; and (e) maintain their own AML compliance program appropriate to their business.

8. Contact

For AML-related inquiries or to report a compliance concern, contact compliance@settlra.io.