Effective Date: 20 January 2026

Purpose

KrypitalX Exchange Inc. maintains a robust Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) framework to ensure full compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the regulations administered by FINTRAC (Financial Transactions and Reports Analysis Centre of Canada).

Our policy prevents the use of KrypitalX’s services for money laundering, terrorist financing, or any other unlawful activity.

1. AML Program Overview

KrypitalX’s AML/CTF program includes:

• Customer Identification (KYC) and risk profiling.
• Ongoing transaction monitoring.
• Record-keeping and reporting.
• Staff training and independent audits.
• Appointment of a dedicated Chief Compliance Officer (CCO).

2. Customer Due Diligence (CDD)

Before providing services, KrypitalX conducts thorough identity verification on all customers:

• Full legal name, date of birth, address, and nationality.
• Government-issued photo identification.
• Proof of residence (bank statement or utility bill).
• For corporate clients: business registration documents, ownership structure, and authorized signatories.

Enhanced Due Diligence (EDD) applies to high-risk individuals, politically exposed persons (PEPs), or jurisdictions with weak AML standards.

3. Ongoing Monitoring

KrypitalX continuously monitors transactions to detect unusual, suspicious, or large activities, including:

• Rapid deposits/withdrawals inconsistent with a customer’s profile.
• Layering of transactions across multiple wallets or accounts.
• Transactions involving sanctioned or high-risk countries.
• Use of mixing/tumbling services or privacy coins.

All suspicious activities are flagged for internal review and, if warranted, reported to FINTRAC via a Suspicious Transaction Report (STR).

4. Record Keeping

In accordance with Canadian law:

• Identification and transaction records are retained for five (5) years after account closure.
• Records include copies of identification, account activity logs, and transaction details.
• All records are securely stored and accessible only to authorized personnel.

5. Reporting Obligations

KrypitalX complies fully with all FINTRAC reporting requirements, including:

• Suspicious Transaction Reports (STRs)
  
• Large Virtual Currency Transaction Reports (LVCTR)
  
• Terrorist Property Reports (TPR)
  
• Threshold Transaction Reports for cash equivalents (where applicable)

6. Sanctions and Screening

We perform real-time screening against:

• The United Nations Sanctions List
  
• The Office of the Superintendent of Financial Institutions (OSFI) lists
• Other international watchlists and politically exposed persons (PEP) databases.

7. Staff Training

All KrypitalX employees and contractors receive mandatory AML/CTF training at onboarding and annually thereafter, including:

• Identifying suspicious behaviors.
• Handling customer due diligence securely.
• Reporting escalation procedures.
• Protecting confidentiality of compliance data.

8. Independent Review

KrypitalX’s AML/CTF program undergoes annual independent audits by external compliance professionals to assess effectiveness and adherence to Canadian laws.

9. Non-Compliance Consequences

Violations of AML/CTF obligations may result in:

• Account suspension or termination.
• Regulatory reporting to FINTRAC or law enforcement.
• Legal proceedings where applicable.

10. Contact for Compliance Inquiries

Chief Compliance Officer (CCO)

KrypitalX Exchange Inc.

compliance@krypitalx.com