Anti-MoneyLaundering (AML) & Know Your Customer (KYC) PolicyTRADING TP LLCEffective Date: 12 February 2026
1. Introduction & Commitment
TRADING TP LLC(“Company”, “we”, “our”, or “us”) is committed to maintaining the higheststandards of integrity, transparency, and compliance in the operation of itsdigital technology platform.
The Company strictlyprohibits the use of its services for money laundering, terrorist financing,fraud, sanctions evasion, tax evasion, corruption, organized crime activity, orany other unlawful conduct.
This AML & KYCPolicy describes the internal compliance framework adopted by the Company toidentify, assess, mitigate, and report financial crime risks in accordance withinternational best practices and risk-based compliance standards
Use of the platformconstitutes acceptance of this Policy.
2. Regulatory Position & Voluntary Compliance
The Company operatesas a digital technology service provider. While it may not be classified as alicensed financial institution in all jurisdictions, the Company voluntarilyimplements internal controls aligned with:
International AML best practices
FATF (Financial Action Task Force) Recommendations
Global sanctions compliance standards
Risk-based compliance principles
Crypto asset compliance methodologies
The Company does notrepresent itself as a licensed financial institution unless explicitly stated.
3. Risk Assessment & Classification
The Company appliesa structured and continuously updated risk assessment model to all useraccounts.
Each account may beassigned a dynamic internal risk score based on factors including, but notlimited to:
Cumulative deposit volume
Total account balance
Withdrawal size and frequency
Account age
Trading velocity
Abnormal profitability patterns
Geographic location and jurisdiction risk
IP address consistency
Device fingerprinting
Multiple account linkage indicators
Blockchain exposure risk
Funding wallet history
Use of anonymization tools
Accounts categorizedas medium or high risk may be subject to enhanced monitoring, manual review,transaction limits, or additional verification requirements.
The Company reservesthe right to reclassify accounts at any time based on updated risk indicators.
4. Mandatory Identity Verification Threshold
Identityverification (KYC) becomes mandatory when:
The total account balance reaches USD 1,000 or more (or equivalent in digital assets), OR
Cumulative deposits exceed USD 1,000, OR
A withdrawal request equals or exceeds USD 1,000, OR
The account triggers internal compliance alerts, OR
The Company determines verification is required based on risk assessment.
Until identityverification is completed:
Withdrawals may be suspended
Trading access may be limited or restricted
The account may be temporarily frozen
Funds may remain restricted until compliance review is completed and risk concerns are resolved
Failure to completeverification within a reasonable timeframe may result in account terminationand fund review in accordance with applicable legal and compliancerequirements.
Attempts tocircumvent verification thresholds, including deposit structuring or use ofmultiple linked accounts, may result in immediate restriction or permanentsuspension.
5. Identity Verification Requirements
Users subject to KYCmay be required to provide:
Valid government-issued identification (passport or national ID)
Selfie verification and biometric liveness check
Proof of residential address issued within 90 days
Source of funds declaration
Proof of ownership of funding wallet
Supporting documentation regarding transaction origin
Additional documents at the Company’s sole discretion
The Company reservesthe right to:
Reject documents that appear altered, incomplete, expired, or inconsistent
Require re-submission of documents
Request updated verification periodically
6. Enhanced Due Diligence (EDD)
Enhanced DueDiligence procedures may be applied to:
High-value or high-frequency accounts
Politically Exposed Persons (PEPs)
Users located in higher-risk jurisdictions
Accounts demonstrating unusual profitability patterns
Accounts associated with high-risk blockchain addresses
Users attempting to avoid compliance thresholds
EDD measures mayinclude:
Bank statements
Tax documentation
Source of wealth documentation
Video verification interviews
Compliance questionnaires
Independent wallet risk assessments
The Company retainsfull discretion in determining when EDD is required.
7. Ongoing Monitoring & Surveillance
The Companycontinuously monitors account activity using automated and manual reviewprocesses to detect:
Rapid deposit and withdrawal cycles
Sudden spikes in trading profits
Coordinated account behavior
Suspicious trading strategies
Sanctions exposure
Blockchain transactions linked to illicit sources
Abnormal transaction velocity
The Company maydelay, suspend, cancel, or reject transactions pending compliance review andrisk assessment.
Monitoring isongoing and not limited to the onboarding stage.
8. Crypto Asset Compliance Controls
Given the use ofdigital assets, the Company may implement blockchain compliance tools to:
Screen wallet addresses against sanctions databases
Identify high-risk or flagged blockchain transactions
Detect exposure to illicit marketplaces or mixers
Analyze wallet clustering behavior
Require re-verification in case of suspicious wallet activity
Funds associatedwith high-risk or illicit blockchain activity may be restricted pendinginvestigation and resolution in accordance with applicable legal standards.
9. Sanctions & Restricted Jurisdictions
The platform is notavailable to:
Individuals or entities listed on international sanctions lists
Residents of embargoed or restricted jurisdictions
Individuals connected to terrorist financing, organized crime, or financial fraud
Users providing false, misleading, or incomplete information
The Company reservesthe right to deny, restrict, or terminate access at its sole discretion,subject to applicable law.
10. Source of Funds & Withdrawal Controls
The Company mayrequire evidence of legitimate source of funds prior to processing withdrawals.
Withdrawals may be:
Subject to manual compliance approval
Delayed for enhanced review
Limited by daily, weekly, or monthly caps
Rejected if compliance standards are not satisfied
The Company mayrequire re-verification for accounts demonstrating significant profitwithdrawals relative to deposited amounts.
Where regulatory,compliance, liquidity, or risk concerns arise, the Company may delay or refusewithdrawals in accordance with applicable law.
11. Internal Compliance Oversight
The Companymaintains structured internal compliance procedures, including:
Risk classification records
Suspicious activity logs
Account investigation reports
Compliance escalation workflows
Audit-ready documentation
Where required byapplicable law, the Company may file Suspicious Activity Reports (SAR) orequivalent reports with relevant authorities.
All complianceactions are documented and retained for audit purposes.
12. Record Retention
All verificationrecords, transaction logs, compliance reviews, and related documentation aresecurely stored for regulatory, audit, and compliance purposes in accordancewith internal retention standards and applicable legal requirements.
13. Cooperation with Authorities
Where legallyrequired, the Company may disclose relevant information to regulatory bodies,law enforcement agencies, or authorized compliance partners.
Such disclosuresoccur without prior notice to the user where permitted by law.
14. Policy Amendments
The Company reservesthe right to amend, update, or modify this Policy at any time.
Continued use of theplatform after publication of updates constitutes acceptance of the revisedPolicy.