Anti-Money Laundering (AML) Policy

Introduction

NavExM is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy establishes our framework for preventing, detecting, and reporting money laundering and terrorist financing activities in accordance with applicable laws and international best practices.

We recognize our responsibility to help prevent the cryptocurrency exchange platform from being used as a vehicle for money laundering, terrorist financing, or other financial crimes. This policy applies to all employees, contractors, customers, and business partners of NavExM.

Purpose and Scope

The purpose of this AML Policy is to:

• Establish clear procedures for identifying and verifying customer identities
• Implement effective systems for monitoring and detecting suspicious transactions
• Ensure timely reporting of suspicious activities to relevant authorities
• Maintain comprehensive records in compliance with legal requirements
• Provide ongoing training to staff on AML obligations and procedures
• Create a culture of compliance throughout the organization

This policy applies to all transactions, products, and services offered by NavExM, including but not limited to cryptocurrency trading, wallet services, peer-to-peer exchanges, and any other digital asset-related activities.

Regulatory Framework

NavExM operates in compliance with AML/CTF regulations applicable in the jurisdictions where we provide services. While the cryptocurrency industry remains largely unregulated in many regions, NavExM voluntarily adheres to international standards including:

• Financial Action Task Force (FATF) Recommendations
• Local anti-money laundering and counter-terrorist financing legislation
• International sanctions regimes and embargo requirements
• Banking and financial services regulatory requirements
• Data protection and privacy regulations

NavExM continuously monitors changes in regulatory requirements and updates its compliance procedures accordingly to maintain the highest standards of regulatory compliance.

Customer Identification and Due Diligence (KYC)

NavExM implements comprehensive Know Your Customer (KYC) procedures to verify the identity of all customers before providing services. Our KYC requirements include:

Individual Customers

• Full legal name as it appears on government-issued identification
• Date of birth and nationality
• Residential address with supporting documentation
• Government-issued photo identification (passport, national ID card, or driver's license)
• Proof of address (utility bill, bank statement, or government correspondence dated within the last three months)
• Selfie or liveness verification to prevent identity fraud
• Source of funds information for high-value transactions

Business Customers

• Legal entity name and registration details
• Business registration certificate or incorporation documents
• Registered business address
• Tax identification number
• Information on beneficial owners (individuals owning more than 25% of the entity)
• Identification documents for authorized signatories and beneficial owners
• Corporate structure and governance documents
• Nature of business activities and expected transaction patterns

Customers must provide accurate and complete information during the registration process. NavExM reserves the right to request additional documentation or information at any time to satisfy our KYC requirements.

Enhanced Due Diligence (EDD)

NavExM applies Enhanced Due Diligence (EDD) measures for customers and transactions that present a higher risk of money laundering or terrorist financing. EDD procedures may be triggered by:

• High-value transactions or account balances
• Customers from high-risk jurisdictions
• Politically Exposed Persons (PEPs) and their close associates
• Complex corporate structures or ownership arrangements
• Unusual transaction patterns or behaviors
• Businesses operating in high-risk sectors
• Non-face-to-face customer relationships

EDD measures may include:

• Additional identification and verification documentation
• Enhanced source of wealth and source of funds verification
• Senior management approval for establishing or continuing business relationships
• Increased transaction monitoring and review frequency
• Detailed business relationship purpose and intended transaction nature
• Third-party verification of information provided

Transaction Monitoring

NavExM maintains sophisticated transaction monitoring systems to detect unusual or suspicious activity. Our monitoring program includes:

Automated Monitoring

• Real-time transaction screening against predefined risk indicators
• Pattern recognition algorithms to identify anomalous behavior
• Threshold-based alerts for unusual transaction volumes or values
• Velocity checks to detect rapid movement of funds
• Geographic risk analysis based on transaction origins and destinations

Manual Review

• Regular review of high-risk accounts and transactions
• Investigation of automated system alerts by compliance officers
• Periodic sampling and testing of transaction data
• Customer behavior analysis and profile updates

Red Flags and Suspicious Indicators

NavExM monitors for various red flags that may indicate money laundering or other illicit activity, including but not limited to:

• Structuring transactions to avoid reporting thresholds
• Rapid movement of funds with no apparent business purpose
• Transactions inconsistent with customer profile or business activities
• Use of multiple accounts or identities
• Reluctance to provide information or documentation
• Transactions involving high-risk jurisdictions or sanctioned entities
• Unusual patterns such as round-number transactions or repetitive amounts
• Mixing of funds from multiple sources with no clear relationship

Suspicious Activity Reporting

When NavExM identifies suspicious activity that may indicate money laundering, terrorist financing, or other financial crimes, we are committed to reporting such activity to the appropriate authorities in accordance with applicable laws.

Internal Reporting Process

• All employees must immediately report suspicious activity to the Compliance Officer
• Reports must include detailed information about the customer, transaction, and reasons for suspicion
• The Compliance Officer evaluates all internal reports and determines appropriate action
• A record is maintained of all internal suspicious activity reports and investigations

External Reporting

• Suspicious Activity Reports (SARs) or equivalent reports are filed with relevant Financial Intelligence Units (FIUs)
• Reports are submitted within the timeframes required by applicable laws
• Customer confidentiality is maintained in accordance with tipping-off provisions
• NavExM cooperates fully with any subsequent investigations

Tipping-Off Prohibition

NavExM strictly prohibits disclosing to customers or other parties that a suspicious activity report has been filed or that an investigation is underway, except as required or permitted by law.

Record Keeping

NavExM maintains comprehensive records of customer information, transactions, and compliance activities in accordance with legal and regulatory requirements.

Types of Records Maintained

• Customer identification and verification documents
• Account opening documentation and agreements
• Transaction records including dates, amounts, currencies, and parties involved
• Internal and external suspicious activity reports
• Risk assessments and enhanced due diligence documentation
• Correspondence and communications with customers
• Training records and compliance program documentation

Retention Period

NavExM retains all required records for a minimum of seven years from the date of the transaction or the end of the business relationship, or such longer period as may be required by applicable law. Records are stored securely and can be retrieved promptly upon request by authorized parties.

Data Security

All records are maintained in secure systems with appropriate access controls, encryption, and backup procedures to ensure confidentiality, integrity, and availability of information.

Risk Assessment

NavExM conducts regular risk assessments to identify, assess, and understand the money laundering and terrorist financing risks associated with our business activities, customers, products, services, transactions, and delivery channels.

Risk Categories

• Customer Risk: Assessment based on customer type, location, behavior, and transaction patterns
• Product/Service Risk: Evaluation of inherent risks in different cryptocurrency products and services
• Geographic Risk: Analysis of risks associated with different jurisdictions and regions
• Delivery Channel Risk: Assessment of risks related to different service delivery methods

Risk-Based Approach

Based on risk assessments, NavExM applies appropriate risk mitigation measures, including enhanced due diligence, increased monitoring, and additional controls for higher-risk situations.

Staff Training and Awareness

NavExM provides comprehensive AML/CTF training to all employees, contractors, and relevant third parties to ensure they understand their obligations and can effectively implement this policy.

Training Program

• Initial onboarding training for all new employees
• Annual refresher training for all staff
• Specialized training for compliance, customer service, and risk management personnel
• Updates on regulatory changes and emerging risks
• Case studies and practical examples of suspicious activity
• Testing and assessment to verify understanding

Training Topics

• Money laundering and terrorist financing typologies
• Red flags and suspicious activity indicators
• KYC and customer due diligence procedures
• Transaction monitoring and reporting requirements
• Record-keeping obligations
• Sanctions screening and compliance
• Consequences of non-compliance

Sanctions Screening

NavExM screens all customers and transactions against relevant sanctions lists and embargo restrictions to prevent providing services to prohibited individuals, entities, or jurisdictions.

Screening Process

• Initial screening of all new customers during account opening
• Ongoing monitoring of existing customers against updated sanctions lists
• Real-time transaction screening to detect sanctioned parties
• Regular updates of sanctions databases from authoritative sources

Sanctions Lists

NavExM screens against sanctions lists maintained by:

• United Nations Security Council
• United States Office of Foreign Assets Control (OFAC)
• European Union sanctions lists
• Financial Action Task Force (FATF) high-risk jurisdictions
• National sanctions authorities in relevant jurisdictions

Match Handling

When a potential match is identified, NavExM immediately freezes the relevant account or transaction and conducts a thorough investigation. If the match is confirmed, NavExM takes appropriate action including account closure, asset freezing, and reporting to relevant authorities.

Politically Exposed Persons (PEPs)

NavExM applies enhanced due diligence measures to customers who are Politically Exposed Persons, their family members, or close associates.

PEP Definition

A Politically Exposed Person is an individual who holds or has held a prominent public function, including but not limited to:

• Heads of state or government
• Senior politicians and government officials
• Senior judicial or military officials
• Senior executives of state-owned enterprises
• Important political party officials

PEP Procedures

• Screening to identify PEPs during customer onboarding and periodically thereafter
• Senior management approval required to establish or continue business relationships with PEPs
• Enhanced due diligence to determine source of wealth and source of funds
• Increased ongoing monitoring of transactions and business relationships
• Regular review and updating of PEP status

Customer Obligations

Customers of NavExM have important obligations to support our AML compliance efforts:

Information Requirements

• Provide accurate, complete, and current information during account opening and throughout the relationship
• Promptly notify NavExM of any changes to personal information, beneficial ownership, or business activities
• Respond to requests for additional information or documentation within specified timeframes
• Cooperate with identity verification procedures including biometric verification

Prohibited Conduct

• Providing false or misleading information
• Using NavExM services for money laundering or terrorist financing
• Structuring transactions to evade reporting requirements
• Using accounts on behalf of sanctioned parties or in sanctioned jurisdictions
• Attempting to circumvent NavExM's compliance procedures

Consequences of Non-Compliance

Failure to comply with these obligations may result in account restrictions, suspension, or termination. NavExM may also report violations to relevant authorities as required by law.

Prohibited Activities

NavExM prohibits the use of its platform for activities that may facilitate money laundering, terrorist financing, or other financial crimes, including but not limited to:

• Drug trafficking and illegal narcotics trade
• Terrorist financing and support for terrorist organizations
• Human trafficking and modern slavery
• Arms trafficking and illegal weapons trade
• Corruption, bribery, and embezzlement of public funds
• Tax evasion and fraud
• Sanctions evasion and embargo violations
• Proceeds from any criminal activity
• Pyramid schemes, Ponzi schemes, and other fraudulent investment schemes
• Mixing or tumbling services designed to obscure transaction origins
• Darknet marketplace transactions
• Ransomware payments and other cyber-extortion activities

Customers found engaging in prohibited activities will have their accounts immediately suspended or terminated, and relevant authorities will be notified as required by law.

Cooperation with Authorities

NavExM is committed to full cooperation with law enforcement agencies, regulatory authorities, and financial intelligence units in their efforts to combat money laundering and terrorist financing.

Cooperation Activities

• Responding promptly to information requests from authorized authorities
• Providing transaction records and customer information as legally required
• Filing required reports including suspicious activity reports and currency transaction reports
• Freezing assets when required by court orders or regulatory directives
• Participating in industry information-sharing initiatives where permitted by law
• Implementing directives and guidance from regulatory authorities

Information Sharing

NavExM shares information with authorities in accordance with applicable laws and data protection regulations, ensuring that customer privacy rights are balanced with compliance obligations.

Policy Amendments

NavExM reviews and updates this AML Policy regularly to ensure it remains effective and compliant with current laws and regulations. We reserve the right to amend this policy at any time.

Review Process

• Annual comprehensive review of the AML program and policy
• Updates in response to regulatory changes or guidance
• Modifications based on risk assessment findings
• Improvements identified through internal audits or external assessments
• Updates reflecting changes in business activities or risk profile

Notification of Changes

Material changes to this policy will be communicated to customers through our website and by email to the address associated with their account. Continued use of NavExM services following policy updates constitutes acceptance of the revised policy.

Contact Information

If you have questions about this AML Policy or need to report suspicious activity, please contact our Compliance Team:

All reports and inquiries are handled with strict confidentiality. NavExM is committed to protecting the identity of individuals who report suspicious activity in good faith.

Last Updated: November 2025
Version: 1.0