AML Policy

Effective date: 17 July 2026

Fluxo is committed to preventing the use of its custodial digital-asset wallet service for money laundering, terrorist financing, sanctions evasion, fraud and other unlawful activity. This Policy describes our risk-based approach to financial-crime compliance.

1. Risk-based controls

We assess risk using information about customers, transactions, digital-asset addresses, geography and the way the Service is used. The level of review and the controls applied may differ according to the risk presented by a particular user or activity.

2. Customer verification

We may verify a customer’s identity and, where appropriate, request additional information about ownership, source of funds, source of wealth or the purpose of activity. Enhanced review may be required where a higher risk is identified. We may decline to open or continue an account if the required information is not provided or cannot be satisfactorily verified.

3. Sanctions, PEPs and adverse information

We may screen customers and relevant activity against sanctions and other compliance data sources. We may apply enhanced review to politically exposed persons, their close associates and family members, or where credible adverse information indicates increased financial-crime risk.

4. Transaction and address monitoring

We monitor relevant activity and digital-asset addresses using internal controls and specialist compliance tools. We may review activity that appears connected to stolen assets, fraud, sanctioned persons or jurisdictions, mixers, darknet markets, scams, ransomware, terrorist financing or other prohibited activity.

5. Sanctions and prohibited use

Fluxo does not provide services to sanctioned persons, persons acting on their behalf, or users in jurisdictions where the Service is prohibited or restricted. We also prohibit any use intended to evade sanctions, conceal illicit proceeds or facilitate unlawful activity.

6. Actions we may take

Where we identify a compliance concern, we may request information, delay or reject a transaction, restrict or suspend access, freeze assets where required, close an account, or make a report or disclosure to the relevant authority where required by applicable law. We may be unable to explain the specific reason for an action where doing so would compromise a review, breach legal obligations or create a security risk.

7. Records and cooperation

We keep records for the period required by applicable law and cooperate with competent authorities when legally required to do so. We also review and update our controls as the Service, technology, risks and legal requirements evolve.

8. Policy updates and contact

For questions about this Policy, contact support@fluxo.app.

We may update this Policy to reflect changes in law, the Service or our risk controls. The current version will be published on this page with the effective date above.