Anti-Money-Laundering (AML) and Counter-Terrorist-Financing Policy

Last updated: 9 July 2026

Ze Broker is a trading name operated by Atlantis Corporates, 88-90 Hatton Garden, London, Holborn, EC1N 8PG, United Kingdom (the “Company”). The Company is committed to the highest standards in the prevention of money laundering, terrorist financing, proliferation financing, sanctions evasion and other financial crime, and to complying with all Applicable Law. This Policy summarises the framework we apply; it is not exhaustive, and certain internal controls are confidential.

1. Legal and Regulatory Framework

We seek to conduct our activities consistently with applicable anti-money-laundering and counter-terrorist-financing laws, regulations, guidance and international standards, including the recommendations of the Financial Action Task Force (FATF).

2. Risk-Based Approach

We apply a risk-based approach to identify, assess, understand and mitigate the money-laundering and terrorist-financing risks to which we are exposed, taking into account risk factors relating to our customers, products and services, transactions, delivery channels and geographies. We maintain a documented risk assessment that is reviewed and updated periodically.

3. Customer Due Diligence (CDD)

We conduct customer due diligence before establishing a business relationship and before customers may access core Services, including identifying the customer and verifying their identity on the basis of reliable and independent sources. We apply simplified due diligence in lower-risk situations and enhanced due diligence (EDD) in higher-risk situations. See our KYC Policy.

4. Beneficial Ownership

For corporate and other legal-entity customers, we take reasonable measures to identify and verify beneficial owners and to understand the ownership and control structure of the customer.

5. Enhanced Due Diligence

We apply enhanced due diligence to higher-risk customers, relationships and transactions, including those involving politically exposed persons (PEPs), higher-risk jurisdictions, unusual or complex transactions, and higher-risk sources of funds.

6. Sanctions and PEP Screening

We screen customers, beneficial owners and, where appropriate, counterparties and wallet addresses against applicable sanctions lists and for PEP status, both at onboarding and on an ongoing basis. We do not establish or maintain relationships, or process transactions, that would breach applicable sanctions, and we block, reject or freeze as required by Applicable Law.

7. Ongoing Monitoring and Transaction Monitoring

We monitor customer relationships and transactions on an ongoing basis, including through blockchain analytics, to identify activity that is unusual, inconsistent with our knowledge of the customer, or indicative of money laundering, terrorist financing or other financial crime.

8. Travel Rule

Where applicable, we comply with the “travel rule”, collecting, verifying and transmitting required originator and beneficiary information in connection with transfers of Digital Assets.

9. Suspicious Activity Reporting

Where we know or suspect, or have reasonable grounds to know or suspect, that a person is engaged in money laundering or terrorist financing, we make the reports required by Applicable Law to the relevant competent authorities, and we may suspend, freeze or terminate accounts and decline transactions pending investigation.

10. Tipping-Off

We do not disclose to a customer or any third party the fact that a report has been or may be made, or that an investigation is being or may be carried out, where such disclosure is prohibited by Applicable Law.

11. Record-Keeping

We retain customer due-diligence records, transaction records and related documentation for at least five (5) years after the end of the business relationship or the date of a transaction, or longer where required by Applicable Law.

12. Governance, MLRO and Training

We maintain an internal compliance function, including a nominated officer responsible for anti-money-laundering compliance, with appropriate authority and resources. We provide ongoing training to relevant personnel and subject our controls to independent review and audit.

13. Prohibited Activity and Consequences

The use of the Platform for money laundering, terrorist financing, sanctions evasion or any other financial crime is strictly prohibited. Breach may result in immediate suspension or termination, freezing of assets, and reporting to, and cooperation with, competent authorities.

14. Contact

Atlantis Corporates, 88-90 Hatton Garden, London, Holborn, EC1N 8PG, United Kingdom. Email: legal@zebroker.com. In the event of any conflict between the English version and a translation, the English version prevails.