Anti-Money-Laundering (AML) & Know-Your-Customer (KYC) Policy

Last Updated: May 20, 2026

IMPORTANT — READ FIRST. Axion Algo Ltd. ("Axion Algo", "we", "our", "us") is a software-as-a-service vendor that licenses a technical-analysis indicator running inside the TradingView charting platform. We are NOT a bank, broker, dealer, exchange, money transmitter, money services business (MSB), payment institution, e-money issuer, fund custodian, investment adviser, virtual-asset service provider (VASP), crypto-asset service provider (CASP), or any other category of regulated financial institution. We do NOT custody client funds, execute trades, transmit or convert value, settle transactions, or provide investment advice. Accordingly, we are NOT a "designated obliged entity", "reporting entity", "regulated person" or equivalent under the U.S. Bank Secrecy Act (BSA), the EU 4th/5th/6th Anti-Money-Laundering Directives (AMLD4/5/6), the UK Money Laundering Regulations 2017 (MLR 2017), the Canadian PCMLTFA, the Australian AML/CTF Act 2006, or any equivalent national anti-money-laundering and counter-terrorist-financing (AML/CTF) statute. This document describes controls that Axion Algo applies on a voluntary basis as a matter of good operating hygiene, to support partners (in particular Institutional-tier subscribers onboarding us as a vendor from a regulated environment), and to detect and refuse criminal misuse of our service. References to specific statutes below are reference standards we voluntarily align with where applicable — they do not constitute an acknowledgement that we are bound by those statutes as an obliged entity.

1. Purpose & Non-Regulated Status

The purpose of this policy is to document the voluntary, AML-aligned controls that Axion Algo applies across customer onboarding, payment acceptance, ongoing monitoring, sanctions screening, recordkeeping, and cooperation with law-enforcement requests. It exists for three reasons:

We accept payments, including crypto payments. Although our payment flows are intermediated by third-party payment service providers, crypto rails carry residual exposure to sanctioned wallets, mixers, and proceeds of crime. We apply controls that reduce that exposure.
Some subscribers require it. Institutional-tier users (proprietary trading firms, family offices, fund managers, regulated brokers) frequently must onboard their software vendors through a vendor-risk-management process that evaluates the vendor's AML hygiene. This policy is the artefact we provide to that process.
We want to refuse criminal misuse. Even though we are not an obliged entity, we have no interest in our service being used by sanctioned persons, designated terrorists, or money launderers, and we apply controls to detect and reject such use.

Axion Algo is NOT subject to the Bank Secrecy Act (31 U.S.C. §§ 5311-5336), the Financial Crimes Enforcement Network (FinCEN) regulations at 31 CFR Chapter X, the EU Anti-Money Laundering Directives (AMLD4 Directive 2015/849, AMLD5 Directive 2018/843, AMLD6 Directive 2018/1673), the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Canadian Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), the Australian Anti-Money Laundering and Counter-Terrorism Financing Act 2006, the FATF Recommendations, or any equivalent regime as an obliged entity. Nothing in this policy shall be construed as Axion Algo holding itself out to be an obliged entity, as accepting regulatory status it does not possess, or as undertaking statutory duties (including statutory SAR-filing duties) that do not in fact apply to it.

2. Scope

This policy applies primarily to:

Institutional-tier subscribers. Full Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) where the risk profile triggers it, plus periodic re-screening.
Crypto-paid subscribers (Starter, Premium or Institutional tier paid in BTC, ETH, USDT, USDC or other supported assets). Wallet-level controls and on-chain analytics may be applied.

For card-paid Starter and Premium subscribers, we apply a KYC-light approach: our payment service provider (Stripe) performs the primary card-and-billing-address verification, and we limit our own collection to e-mail, IP address, country of access, and device fingerprint for fraud and abuse detection. Card-paid users in this tier are not required to provide identity documents unless a risk-based trigger (sanctions hit, chargeback pattern, account layering) escalates the relationship.

3. Risk-Based Approach

Aligned with FATF Recommendation 1 (assessing risks and applying a risk-based approach), Axion Algo classifies users into three risk tiers. The tier determines what onboarding evidence is required, what screening cadence applies, and whether senior-management approval is required.

3.1 Low risk

Card-paid Starter or Premium subscribers.
Residing in low-risk jurisdictions (FATF compliant, no greylist or blacklist exposure, no comprehensive sanctions program).
No politically-exposed-person (PEP) status.
No adverse-media or sanctions screening hit.
No flagged occupation.

3.2 Medium risk

Crypto-paid subscribers regardless of tier.
Residing in mid-risk jurisdictions (no comprehensive sanctions but on a watchlist of a major standard-setter).
Occupations not flagged but with elevated cash exposure.
Limited public footprint making identity verification harder.

3.3 High risk

Institutional-tier subscribers (entities and their signatories).
PEPs, family members of PEPs, close associates of PEPs.
Users in high-risk jurisdictions (FATF grey-list, FATF black-list, or jurisdictions subject to FATF call-for-action).
Occupations associated with cash-intensive businesses (money-services bureau operators, casino employees, dealers in high-value goods, real-estate intermediaries) where the occupation is independently identified.
Any user where a sanctions probable-match, adverse-media hit, or behavioural red flag has been raised and not yet cleared.

4. Customer Due Diligence (CDD)

CDD is applied at signup, at upgrade to a higher tier, on suspicion, and on periodic re-screening. The evidence collected depends on the payment rail.

4.1 Card-paid users

Stripe, as our payment service provider, verifies card number, card expiry, CVC, postal code / billing address, and runs its own fraud-and-abuse screening (Radar). Axion Algo itself records:

E-mail address.
IP address at signup and at each session start.
Country of access, time zone, language preference.
Device fingerprint (user agent, browser hash).
Stripe customer ID and last-four card digits.

4.2 Crypto-paid users

For crypto subscriptions, we record:

The wallet address that the user enters as the originating wallet (where the checkout flow asks for it).
The on-chain transaction hash of the payment.
The blockchain network (Bitcoin, Ethereum, Tron, etc.).
The exchange fingerprint where derivable (e.g., the hot-wallet cluster from which the deposit originated).
The asset and amount, valued in USD at the moment of payment.

5. Enhanced Due Diligence (EDD)

Where a user is classified as high risk per Section 3.3, we apply Enhanced Due Diligence. EDD requires, in addition to the standard CDD evidence:

Full legal name (as it appears on government-issued ID).
Date of birth.
Nationality.
Government-issued identity document: passport (preferred) or national identity card. The document must be unexpired and machine-readable.
Proof of address dated not more than three months from the date of submission: utility bill, bank statement, tax notice, or government correspondence showing the user's name and residential address.
Source-of-funds declaration: a short written statement identifying the legitimate origin of the funds used to pay Axion Algo (salary, business income, investment proceeds, inheritance, etc.).
Where the user is an entity, beneficial-ownership information identifying every natural person owning or controlling 25% or more of the entity, plus the persons exercising ultimate effective control.

EDD evidence is reviewed by the Founder acting as compliance lead (see Section 15) and the relationship may not be opened or upgraded until that approval is recorded.

6. Know Your Customer (KYC) for Institutional Tier

Institutional-tier onboarding requires the following documents in addition to the EDD evidence in Section 5:

6.1 Entity documents

Certificate of Incorporation (or equivalent constitutional document) issued by the relevant company registry.
Memorandum and Articles of Association (or constitution, bylaws, partnership agreement, trust deed, as applicable).
Current register of directors / managers / general partners / trustees.
Register of beneficial owners holding 25% or more, with the ownership / control chain back to natural persons.
Tax identification number (EIN, VAT number, UTR, ABN, or equivalent).
Where applicable, regulatory licence or registration number (FINRA, FCA, ASIC, BaFin, AMF, CSA, MAS, SFC, FINMA, etc.).

6.2 Individual signatory

Valid unexpired passport (preferred) or national ID card.
Proof of address dated not more than three months.
Sworn declaration of authority to bind the entity (board resolution, power of attorney, or signed authorisation letter on entity letterhead).

6.3 Source of funds

Bank reference letter from a regulated bank in the entity's jurisdiction, OR
Most recent audited financial statements, OR
Equivalent evidence acceptable to Axion Algo's compliance lead (e.g., independent auditor letter, regulator-published financial filings, redacted prime-broker statement).

7. Sanctions Screening

At onboarding and on a continuous basis thereafter, Axion Algo screens user names, entity names, beneficial owners, and (where captured) crypto wallet addresses against the consolidated lists published by the following authorities:

U.S. Department of the Treasury — Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List (SDN List).
OFAC Consolidated Sanctions List (Sectoral Sanctions Identifications, Foreign Sanctions Evaders, Non-SDN Palestinian Legislative Council, Non-SDN Menu-Based Sanctions, and related lists).
European Union Consolidated List of persons, groups and entities subject to EU financial sanctions.
United Kingdom HM Treasury Office of Financial Sanctions Implementation (OFSI) Consolidated List of Financial Sanctions Targets.
United Nations Security Council Consolidated List.
Where commercially feasible, additional national lists relevant to a user's jurisdiction (DFAT Australia, OSFI Canada, SECO Switzerland, METI Japan, etc.).

Where commercially feasible, screening is performed by a third-party provider (for example ComplyAdvantage, Refinitiv World-Check, Trulioo, Sanctions.io or equivalent) configured for automated continuous screening so that designations added after onboarding are detected without manual intervention.

7.1 Match resolution

Probable match. Access to the service is immediately frozen pending manual review by the compliance lead. The user's indicator licence is disabled within the TradingView entitlement system.
False match. Where review confirms the hit is a false positive (name collision, dated record, mistaken identity), access is restored and a record of the decision is retained for the period set out in Section 13.
Confirmed match. Where the hit is confirmed, the relationship is terminated, refunds are not issued where legally prohibited, the matter is escalated to the applicable competent authority on a voluntary basis (see Section 11), and access is permanently revoked. Axion Algo does not custody assets, so no asset freeze is operationally required at our level; we nevertheless cooperate with downstream freezing requests from authorities or payment providers.

8. Politically Exposed Persons (PEPs)

Axion Algo screens for politically-exposed-person status using the FATF Glossary definition, covering:

Domestic PEPs — natural persons entrusted with prominent public functions in the user's country of residence.
Foreign PEPs — natural persons entrusted with prominent public functions by a foreign country.
International organisation PEPs — senior management of an international organisation (directors, deputy directors, board members, equivalent).
Family members — spouses, civil partners, parents, siblings, children of the PEP, and spouses or partners of the children.
Close associates — natural persons known to have joint beneficial ownership, close business relationships, or sole beneficial ownership of a legal entity set up for the benefit of the PEP.

PEP status (including former-PEP status, where the prominent function ended less than 12 months ago) triggers Enhanced Due Diligence per Section 5 and requires senior-management approval before onboarding or before continuation where the status is identified post-onboarding.

9. Adverse Media Screening

For high-risk users (Section 3.3) Axion Algo periodically searches credible media sources for reports linking the user to financial crime, fraud, corruption, market manipulation, sanctions evasion, terrorism financing, human trafficking, or organised crime. Adverse media screening is performed through the same third-party provider used for sanctions screening where available, supplemented by manual searches of major news outlets in relevant languages.

Adverse-media hits do not automatically result in termination but trigger documented review by the compliance lead, who decides whether to apply additional EDD, restrict the relationship, or terminate it.

10. Transaction & Behaviour Monitoring

Although Axion Algo does not process value transfers between users and is not a payment intermediary, we do monitor account behaviour for indicators of misuse that, in a regulated firm, would constitute typologies of money laundering, fraud, or sanctions evasion. Indicators include:

Multiple accounts created from the same IP address, device fingerprint, or payment method within a short period (potential structuring or licence-fraud).
Use of disposable e-mail addresses combined with VPN exit-nodes, crypto payment, and rapid IP geolocation rotation.
Rapid signup → upgrade → chargeback or rapid signup → refund cycles inconsistent with normal product use.
Discord messages (in our community server) soliciting or offering "money mule" services, account-renting, payment-fronting, or sanctioned-jurisdiction proxy services.
Affiliate-program signup patterns consistent with fraud rings: tight referral chains, payout routing through a single beneficial owner, synthetic-identity referees.
Crypto payments originating from wallets that on-chain analytics flag as associated with mixers, sanctioned addresses, hacks, ransomware payouts, or darknet markets.

11. Suspicious Activity Reports (SARs)

Where Axion Algo observes activity that, in the hands of a regulated obliged entity, would give rise to a statutory Suspicious Activity Report (SAR), Suspicious Transaction Report (STR), or equivalent filing obligation — for example, where a user appears to be using our service as part of a layered money-laundering scheme, a sanctions-evasion arrangement, or a terrorism-financing typology — we may, on a discretionary basis:

Terminate access immediately and disable the user's TradingView entitlement.
Preserve records, including server logs, payment metadata, on-chain identifiers, Discord activity, and CDD/EDD/KYC files.
Report the matter on a voluntary basis to the applicable law-enforcement authority or financial intelligence unit (for example FinCEN in the United States via the BSA E-Filing system, the UK National Crime Agency via the SAR Online portal, FIU-NL in the Netherlands via goAML, AUSTRAC via its online channel, or the equivalent FIU in the user's jurisdiction).

Axion Algo is not under a statutory SAR-filing obligation and any such voluntary disclosure is made in the public interest and to protect the integrity of our service. Voluntary disclosure does not constitute an admission that Axion Algo is an obliged entity.

12. No Tipping Off

Where Axion Algo cooperates with a law-enforcement request or files a voluntary SAR-equivalent disclosure, we do not notify the user that an investigation is ongoing, that records have been disclosed, or that their account has been flagged, except where required by law. Some jurisdictions require notice to the data subject within a defined period; where such a rule applies, we comply with the strictest applicable rule. Where the requesting authority orders non-disclosure or where applicable law prohibits tipping off (for example, sections 333A & 342 of the UK Proceeds of Crime Act 2002, or 18 U.S.C. § 1510 in the United States), we comply with the prohibition.

13. Recordkeeping

Axion Algo retains the following records for a minimum period of five (5) years from the end of the customer relationship, aligned with FATF Recommendation 11 and the retention standards of the principal AML statutes referenced in Section 18:

CDD and EDD files (Sections 4 and 5).
KYC documents for Institutional subscribers (Section 6).
Sanctions, PEP, and adverse-media screening hits and resolution decisions (Sections 7-9).
Payment metadata, including Stripe records and on-chain hashes.
Behavioural-monitoring alerts and dispositions (Section 10).
SAR-equivalent voluntary disclosures and supporting evidence (Section 11).
Correspondence with law-enforcement and supervisory authorities (Section 16).

Where a record is subject to a longer statutory retention period in any jurisdiction the user resides in, the longer period applies. Records are stored encrypted at rest and access-controlled to compliance personnel.

14. Training

Internal staff (including contractors) with access to onboarding, payment, billing, or compliance functions receive annual training covering:

AML and CTF red flags relevant to a SaaS subscription business.
Sanctions screening workflow and match-resolution.
PEP identification and Enhanced Due Diligence.
This policy and any updates to it.
The tipping-off prohibition and the boundaries of permitted internal discussion of suspicious-activity matters.

Training completion is logged. At present (May 2026) the training cohort comprises the Founder and a small number of contractor operators; as the team grows the training programme will scale accordingly.

15. Independent Review

This policy and the controls it describes are reviewed at least annually by Axion Algo's compliance lead. At the date of this policy the compliance lead is the Founder, acting personally, until such time as Axion Algo's Institutional book reaches a scale that justifies the appointment of a designated Money Laundering Reporting Officer (MLRO) or equivalent compliance officer. Where Institutional subscribers reasonably require it as part of their vendor-risk-management process, Axion Algo will engage an independent third-party reviewer (such as a law firm or a specialist compliance consultancy) to attest to the operation of these controls, at the subscriber's expense or on commercial terms to be agreed.

16. Cooperation with Law Enforcement

Axion Algo responds to valid subpoenas, court orders, mutual legal assistance treaty (MLAT) requests, and other lawful government requests in accordance with applicable law. Our standing practice is to:

Verify the validity, jurisdiction, and scope of the request, including verifying the issuing authority and the legal basis cited.
Disclose only the minimum information required to comply, scoped tightly to the user, date range, and data categories specified.
Where the request is over-broad, push back through counsel and require narrowing.
Where the request originates from a jurisdiction other than the jurisdiction of the user or of Axion Algo, evaluate whether an MLAT or equivalent mechanism is required.
Decline to provide notice to the user where the request explicitly prohibits notice, where applicable law prohibits tipping off (Section 12), or where notice would substantially frustrate the investigation; otherwise apply the policy described in our Privacy Policy regarding subject notification.

17. Crypto Payment Specific Controls

For crypto subscriptions Axion Algo applies controls in addition to those described above:

Front-end KYC by the payment processor. We use a regulated or self-declared compliant crypto-payment processor (for example NOWPayments, Coinbase Commerce, BitPay, or equivalent) that performs its own KYC, sanctions screening, and wallet screening at the point of payment.
Wallet recording. Wallet addresses associated with a successful payment, together with transaction hash, network, asset and amount, are recorded against the user account.
On-chain analytics. Axion Algo may at its discretion use on-chain analytics tools (such as Chainalysis, Elliptic, TRM Labs or equivalent) to flag wallets associated with mixers, tumblers, sanctioned addresses, exchange hacks, ransomware payouts, or darknet-market clusters.
Tainted-wallet handling. Where a wallet is flagged as tainted, the subscription is terminated. A refund may be issued where operationally possible and where doing so does not itself violate sanctions or AML rules; otherwise the funds are quarantined pending guidance from counsel or the relevant authority.
Travel Rule (FATF Recommendation 16). Where the crypto transfer equals or exceeds the USD 3,000 threshold referenced in FinCEN's rule at 31 CFR 1010.410(f) (or such lower threshold as is set by the EU Transfer of Funds Regulation (EU) 2023/1113, the UK MLR amendments transposing the Travel Rule, or the user's local equivalent), originator and beneficiary information may be required. Because Axion Algo receives payment rather than transmits value, the Travel Rule obligation generally applies to the sending VASP and not to us; Axion Algo nevertheless cooperates with VASP information requests directed at it as the receiving counterparty's merchant.

18. Country-Specific AML Equivalents — Reference Standards

Axion Algo voluntarily aligns its controls, where applicable, with the following national and supranational AML frameworks. Inclusion of a regime in this list does not constitute an acknowledgement that Axion Algo is an obliged entity under that regime.

United States. Bank Secrecy Act (31 U.S.C. §§ 5311-5336), FinCEN regulations (31 CFR Chapter X), USA PATRIOT Act, and the OFAC sanctions program administered by the U.S. Department of the Treasury. We are not a money services business under 31 CFR 1010.100(ff) but apply MSB-aligned hygiene.
European Union. AMLD4 (Directive (EU) 2015/849), AMLD5 (Directive (EU) 2018/843), AMLD6 (Directive (EU) 2018/1673), Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets (Travel Rule), Markets in Crypto-Assets Regulation (MiCAR, Regulation (EU) 2023/1114) where applicable.
United Kingdom. Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), Proceeds of Crime Act 2002 (POCA), Terrorism Act 2000, Sanctions and Anti-Money Laundering Act 2018.
Canada. Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), the regulations made thereunder, and guidance issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
Australia. Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) and rules, AUSTRAC guidance.
Singapore. Monetary Authority of Singapore Notice PSN02 (Prevention of Money Laundering and Countering the Financing of Terrorism — Holders of Payment Services Licence for Digital Payment Token Services) and the Payment Services Act 2019.
Hong Kong. Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).
Switzerland. Federal Act on Combating Money Laundering and the Financing of Terrorism in the Financial Sector (AMLA / GwG), FINMA Anti-Money Laundering Ordinance.
Brazil. Law 9,613/1998 (as amended by Law 12,683/2012) and guidance issued by the Council for Financial Activities Control (COAF).
United Arab Emirates. Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations, the Central Bank of the UAE rulebook on AML/CFT, and VARA rules where applicable.

19. Country Restrictions

Axion Algo does NOT onboard users from comprehensively sanctioned jurisdictions, nor from regions subject to comprehensive sanctions programs. Restricted jurisdictions and regions currently include:

Iran (Islamic Republic of)
Democratic People's Republic of Korea (DPRK / North Korea)
Cuba
Syria
The Crimea region, and the so-called Donetsk People's Republic, Luhansk People's Republic, Zaporizhzhia and Kherson regions of Ukraine
Venezuela (on a sectoral basis per the OFAC program)
The Russian Federation and Belarus (on a sectoral basis per current OFAC, EU, and UK sectoral programs; comprehensive bans apply to specifically listed persons, entities, and economic sectors)

Users from jurisdictions on the FATF grey-list (jurisdictions under increased monitoring) or black-list (high-risk jurisdictions subject to a call for action) may be accepted but are subject to Enhanced Due Diligence (Section 5) and senior-management approval. The list of restricted jurisdictions is updated as sanctions programs evolve; the current list is maintained at /legal/restricted-jurisdictions and prevails over the list reproduced in this section in case of conflict.

20. PEP Recourse

A user who believes that they have been wrongly classified as a PEP, or who believes that PEP-related EDD requirements have been applied to them in error, may submit corrective evidence to our contact form. Senior review is conducted within ten (10) business days of receipt of complete evidence. Where the classification is confirmed as erroneous, the PEP flag is removed and any EDD-driven restrictions are lifted.

21. Recourse if Wrongly Flagged or Sanctions Match Disputed

A user who disputes a sanctions match or an AML-driven termination of access may submit, in writing to our contact form, evidence of the kind that OFAC accepts in a delisting petition:

A clear statement explaining why the match is believed to be false (name collision, date-of-birth mismatch, jurisdictional mismatch, mistaken identity).
Government-issued identity documents establishing the user's true identity.
Proof of address.
A sworn statement (signed under penalty of perjury where the user's jurisdiction permits) attesting to the foregoing.
Any other evidence the user considers relevant (regulatory standing, professional licences, prior compliance attestations).

Axion Algo re-screens within ten (10) business days of receipt of complete evidence. Where re-screening confirms a false match, access is restored and a written apology is issued. Where re-screening confirms a true match, the termination stands and the matter is escalated to the applicable competent authority on a voluntary basis.

22. Annual Compliance Statement

Axion Algo's leadership publishes an annual statement attesting that the controls described in this policy have been operated as described over the preceding twelve-month period. At the present stage of the company the statement is prepared internally and is made available externally on request from an active Institutional subscriber under a non-disclosure agreement. As the Institutional book grows, the statement may be subject to independent third-party assurance (see Section 15).

23. Modifications

Axion Algo reserves the right to modify this policy at any time. Material changes (changes to scope, to the risk classification framework, to the categories of evidence required, to the restricted-jurisdictions list, or to the recourse mechanism) are notified to active Institutional subscribers at least thirty (30) days in advance of effect, by e-mail to the contact of record. Minor changes (clarifications, drafting corrections, statute citation updates) take effect upon posting of the updated policy. The "Last Updated" date at the top of this document is the authoritative indicator of the version in force.

24. Contact

AML and KYC matters, including dispute of sanctions matches, PEP classification, and Institutional onboarding requests, should be directed to our contact form. General product or billing queries should be directed to our contact form.

25. Cross-References

This policy is to be read together with the following Axion Algo documents, each of which prevails over this policy within its own subject-matter: