Legal — Anti-Money Laundering (AML) Policies and Regulations

AML/CFT Policy

Last updated: 4 June 2026

Customer Identification

XFortuit is required to comply with regulatory client identification requirements. This includes the collection of identification information such as full name, address, date of birth, national ID number or passport, as well as other pertinent information to identify the person.

Risk-Based Approach

XFortuit applies a risk-based approach to anti-money laundering and counter-terrorist financing. Clients, products and transactions are assessed and classified according to risk, and the level of due diligence and monitoring applied is proportionate to that risk. Risk classifications are reviewed periodically and whenever relevant circumstances change.

Sanctions and PEP Screening

Clients are screened at onboarding and on an ongoing basis against applicable international sanctions lists and against lists of politically exposed persons (PEPs). XFortuit does not provide services to individuals or entities subject to applicable sanctions, and relationships with PEPs are subject to enhanced due diligence and senior management approval.

Transaction Monitoring

XFortuit monitors its clients' transactions to detect any suspicious activity. This includes transactions that can be indicative of money laundering or terrorist financing. As well, the brokerage must keep and record this information for a minimum of five years.

Customer Due Diligence

XFortuit performs full due diligence. This includes verifying both source of revenue and the source of funds. XFortuit reserves the right to decline to open accounts or perform transactions on behalf of customers who are not subject to due diligence.

Third-Party Payments

Deposits must originate from a payment method or account held in the name of the account holder. Payments from third parties are not accepted and will be returned to the originating source where possible. Withdrawals are returned to the same payment method used for the deposit, in the name of the account holder, to the extent permitted by the payment provider. Anonymous payments and payments in cash are not accepted under any circumstances.

Refusal, Suspension and Reporting

XFortuit reserves the right to refuse to process a transaction at any stage where it suspects a connection to money laundering, terrorist financing or other criminal activity, to suspend or terminate the business relationship, and to freeze funds where required. Suspicious activity is reported to the competent authorities, and XFortuit may be prohibited by law from informing the client that a report has been made.

Employee Training

Everyone in the XFortuit group is trained to recognize and report suspicious activity. They must follow strict anti-money laundering procedures and raise any concerns with their in-house compliance department.

Access to Confidential Information

Access to confidential information is only authorized for employees who require it to do their work. Such employees are responsible for signing confidentiality agreements and following proper security procedures.

Communication to Regulators

XFortuit collaborates with local regulators to prevent and fight money laundering. This includes the reporting of suspicious activity and the provision of information where appropriate.

XFortuit undertakes to ensure that its commercial activities abide by all applicable laws and regulations. The fight against money laundering and the financing of terrorism is an essential element of the company and we are committed to maintaining the highest standards of integrity and compliance.

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