AML Policy

This AML Policy summarises the Anti‑Money Laundering and Counter‑Terrorist Financing ("AML/CTF") compliance programme APEXTRADE applies to every account and transaction on its platform. It supplements our Terms & Conditions and our Fraud Policy, which describes fraud‑specific controls and how to report suspicious activity.

Our programme is built to comply with the Polish Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, the EU Anti‑Money Laundering Directives, applicable EU and UN financial sanctions regimes, and — as it becomes applicable to our activities — Regulation (EU) 2023/1114 (MiCA) and its accompanying AML framework. As disclosed in our Terms & Conditions, APEXTRADE currently operates under a virtual‑currency‑service registration in Poland rather than full CASP authorisation under MiCA.

We assess money‑laundering and terrorist‑financing risk at both customer and transaction level, taking into account factors such as customer type, geographic exposure, product usage, and transaction behaviour. Higher‑risk customers and activity are subject to enhanced controls, while lower‑risk relationships are monitored proportionately.

Before providing Services, we identify and verify each customer using:

• government‑issued identification and biometric/selfie verification;
• proof of address where required by risk level;
• screening against sanctions, politically‑exposed‑person (PEP), and adverse‑media lists; and
• where appropriate, information on the source of funds or source of wealth.

Enhanced due diligence is applied to PEPs and their close associates, customers connected to higher‑risk jurisdictions, and relationships presenting elevated risk indicators, and may include senior management approval before onboarding.

We monitor transactions on an ongoing basis to detect activity inconsistent with a customer's profile or with typical use of our Services, and periodically refresh customer information based on risk. Records of identification data and transaction history are retained for 5 years following the end of the business relationship, in line with Article 49 of the Polish AML Act, or longer where required by other applicable law.

All customers and transactions are screened against EU, UN, and other applicable sanctions lists before onboarding and on an ongoing basis. We do not knowingly provide Services to sanctioned individuals or entities, or to persons in jurisdictions subject to comprehensive sanctions that would prevent us from lawfully serving them.

Where our review identifies reasonable grounds for suspicion of money laundering or terrorist financing, we are legally required to file a report with Poland's Financial Intelligence Unit (Generalny Inspektor Informacji Finansowej, "GIIF") without notifying the customer concerned. Tipping off a customer about a report or underlying investigation is prohibited by law, and we cannot confirm or deny whether a report has been made regarding any account.

Our AML/CTF programme is overseen by designated compliance personnel responsible for policy governance, escalation of high‑risk cases, and liaison with GIIF and other competent authorities. Staff involved in onboarding, transaction review, and customer support receive regular AML/CTF training appropriate to their role.

We may delay, decline, or reverse a transaction, or restrict or close an account, where necessary to comply with AML/CTF law, respond to a request from GIIF or another competent authority, or manage an unresolved risk identified through due diligence or monitoring.

This Policy is reviewed periodically and updated to reflect changes in law, regulatory guidance, and our own risk assessment. The current version is always available on this page.

Questions about this AML Policy can be sent to info@tiontrade.com. To report suspected fraud or suspicious activity, see our Fraud Policy.