Anti-Money Laundering (AML) & Counter-Financing of Terrorism (CFT) Policy

1. Our Commitment

FluxRail is committed to the highest standards of compliance with anti-money laundering (AML), counter-financing of terrorism (CFT), and economic sanctions laws. We operate a risk-based compliance program designed to detect, prevent, and report money laundering, terrorist financing, sanctions evasion, fraud, and other financial crime across our products — blockchain monitoring, transfers, asset conversion, and cross-border payouts.

2. Regulatory Status

FluxRail is registered with the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) as a Money Services Business (MSB). We maintain our AML/CFT program in accordance with the Bank Secrecy Act (BSA) and its implementing regulations, and we work with licensed banking and payment partners whose own regulatory obligations also apply to transactions processed through FluxRail.

3. AML/CFT Program

Our program is built on the five pillars expected of a regulated financial institution:

• Designated Compliance Officer: a qualified officer is responsible for the day-to-day oversight and administration of the AML/CFT program.
• Internal policies, procedures & controls: risk-based controls covering onboarding, screening, monitoring, escalation, and reporting.
• Ongoing training: relevant staff receive regular AML/CFT and sanctions training.
• Independent testing: the program is periodically reviewed and tested.
• Customer Due Diligence (CDD): risk-based verification of every customer, with Enhanced Due Diligence (EDD) for higher-risk customers and activity.

4. Know Your Customer (KYC) & Business (KYB)

Customers of our payment and payout products are subject to identity verification before they can transact. FluxRail collects identity information once and verifies it against authoritative sources and our partners. For individuals this includes name, date of birth, address, and government identity data (for example, BVN/NIN in Nigeria, or document + liveness verification elsewhere). For businesses (KYB), this includes legal entity information and beneficial-ownership data. You must provide accurate, truthful, and current information; FluxRail may re-verify at any time and may refuse, suspend, or terminate service where verification cannot be completed.

5. Sanctions Screening

Every customer and every payout beneficiary is run through automated sanctions and watchlist screening before settlement. FluxRail screens against applicable lists — including those administered by the U.S. Office of Foreign Assets Control (OFAC), the United Nations, the European Union, the UK (HMT/OFSI), and other relevant authorities — as well as politically-exposed-person (PEP) and adverse-media data.

Screening is performed using established sanctions-data and AML providers, including OpenSanctions and other leading watchlist and adverse-media data sources, combined with FluxRail's own matching and review logic. Any potential match is automatically held and routed to manual compliance review; senior approval with a written, audited justification is required before a held transaction can proceed. We do not facilitate transactions for sanctioned individuals, entities, or jurisdictions, and screening runs continuously — not only at onboarding.

6. Transaction Monitoring & Approval

Transactions are monitored on a risk basis for unusual or suspicious patterns. Payouts pass through an approval gate before any funds move, and FluxRail may request additional information, delay, or decline a transaction to meet its compliance obligations. We apply velocity, amount, and behavioral controls and may impose limits based on a customer's risk profile and verification level.

7. Recordkeeping & Reporting

FluxRail retains customer identification, transaction, and screening records for the periods required by applicable law. Where required, we file reports with the appropriate authorities, including Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs), and we cooperate with lawful requests from regulators and law enforcement. Consistent with the BSA, we do not disclose to a customer or any third party that a SAR has been or may be filed.

8. Merchant & Integrator Obligations

If you integrate FluxRail to serve your own end-users, you are responsible for ensuring your use of the platform complies with all applicable laws in the jurisdictions where you operate. You must not use FluxRail to facilitate transactions for individuals or entities subject to sanctions, to launder proceeds of crime, to finance terrorism, or for any unlawful purpose. You agree to cooperate with FluxRail's compliance requests, including providing information about your end-users where required.

9. Prohibited Activity

• Money laundering, terrorist financing, or sanctions evasion in any form.
• Transactions involving sanctioned persons, entities, or comprehensively sanctioned jurisdictions.
• Fraud, scams, or transactions involving proceeds of illegal activity.
• Use of the platform to evade identity verification or to obscure the source or destination of funds.

10. Contact

Compliance, law-enforcement, and regulatory inquiries may be directed to [email protected]. This policy is reviewed regularly and may be updated to reflect changes in law, regulation, or our risk assessment.