AML & KYC Policy

SECTION C: ANTI-MONEY LAUNDERING (AML) & TERRORIST FINANCING (CTF) POLICY

1. AML COMMITMENT AND LEGAL FRAMEWORK

WILDX LIMITED maintains a zero-tolerance policy towards money laundering, terrorist financing, tax evasion, and sanctions evasion. Our framework is built upon the Proceeds of Crime Act 2002 (POCA), the Terrorism Act 2000, and the FATF (Financial Action Task Force) Recommendations.

2. RISK-BASED CUSTOMER DUE DILIGENCE (CDD)

2.1. We employ a dynamic, risk-based approach to customer onboarding.
2.2. Verification Tiers:

• Tier 0: Unverified. No fiat or crypto transactions allowed.
• Tier 1 (Standard CDD): Verified ID and email. Subject to strict daily and monthly transaction limits.
• Tier 2 (Advanced CDD): Verified ID, Proof of Address (utility bill < 3 months), and Biometric Liveness check. Required for card issuance and higher transaction limits.

3. ENHANCED DUE DILIGENCE (EDD) PROCEDURES

3.1. EDD is a highly rigorous investigative procedure applied to high-risk profiles.
3.2. EDD Triggers: EDD is automatically triggered if:

• You are identified as a Politically Exposed Person (PEP), a relative of a PEP, or a close associate (RCA).
• You reside in, or transact with, a High-Risk Jurisdiction (e.g., countries on the FATF Grey List).
• You execute transactions that are unusually large, complex, or lack a clear economic rationale.
• You interact with high-risk Merchant Category Codes (e.g., Crypto Exchanges, Gambling). 3.3. EDD Requirements: During an EDD investigation, you must immediately provide:
• Source of Wealth (SoW): Auditable proof of how your total net worth was generated (e.g., inheritance tax forms, company dividend certificates, real estate sale contracts).
• Source of Funds (SoF): Auditable proof of the specific origin of the funds used in a transaction (e.g., bank statements showing salary deposits). 3.4. Failure to provide satisfactory EDD documentation within 14 business days will result in the permanent termination of your Account and the freezing of all assets.

4. REAL-TIME TRANSACTION MONITORING AND BLOCKCHAIN ANALYTICS

4.1. Fiat Monitoring: Our systems flag velocity spikes, structuring (smurfing), and anomalous behavioral patterns.
4.2. Crypto Traceability: We utilize specialized blockchain forensics tools (e.g., Chainalysis, Elliptic) to trace the provenance of all cryptocurrency deposits.
4.3. If our forensics indicate your funds have interacted with darknet marketplaces, ransomware addresses, sanctioned entities, or cryptographic mixing services (e.g., Tornado Cash), the funds will be quarantined indefinitely.

5. GLOBAL SANCTIONS SCREENING

5.1. Every User, along with their counterparties, is screened continuously against global consolidated sanctions lists, including:

• UK HM Treasury (HMT)
• US Office of Foreign Assets Control (OFAC) SDN List
• European Union (EU) Restrictive Measures
• United Nations Security Council (UNSC) 5.2. In the event of a positive sanctions match, WILDX LIMITED is legally obligated to freeze the Account immediately and report the assets to the Office of Financial Sanctions Implementation (OFSI).

6. SUSPICIOUS ACTIVITY REPORTS (SAR) AND THE STRICT PROHIBITION ON "TIPPING OFF"

6.1. If we know, suspect, or have reasonable grounds to suspect that funds are the proceeds of criminal conduct, we are legally mandated to file a Suspicious Activity Report (SAR) with the National Crime Agency (NCA) in the UK.
6.2. The "Tipping Off" Offense: Under section 333A of the Proceeds of Crime Act 2002, it is a criminal offense punishable by imprisonment for any employee of WILDX LIMITED to disclose to a User that a SAR has been filed or that a money laundering investigation is underway.
6.3. Consequently, if your Account is frozen pending an internal or external investigation, our customer support team will NOT provide you with the specific reasons for the freeze, nor will they inform you of any communication with law enforcement. You explicitly agree to this procedural opacity as a condition of using our Services.