INTRODUCTION
This Anti-Money Laundering and Counter-Terrorist Financing Policy (hereinafter referred to as the “Policy”) of Axis Protocol Inc., a company incorporated under the laws of Canada, under the Company number 2027786017, having its legal and business address at: 700-602 12 AVE SW, Calgary, Alberta, T2R1J3, Canada, represented by the Director Roman Moroz (hereinafter referred to as the “Company”, “We”, or “Us”), was prepared in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (hereinafter referred to as the “PCMLTFA”), as well as other pertinent regulations relating to anti-money laundering (hereinafter referred to as the “AML”) and counter-terrorist financing (hereinafter referred to as the “CTF”), including the Financial Action Task Force (hereinafter referred to as the “FATF”) Recommendations.
Axis Protocol Inc. operating in accordance with the PCMLTFA, is fully committed to maintaining a robust and transparent compliance framework for all Clients of its over-the-counter (hereinafter referred to as the “OTC”) crypto-assets exchange services (hereinafter referred to as the “Services”).
Please refer to the Company’s other policies, such as Terms of Use, to learn more about the Company’s Services.
This Policy sets out the Company’s commitment to preventing the use of the Company’s Services for illicit financial purposes, including money laundering (hereinafter referred to as the “ML”), terrorist financing (hereinafter referred to as the “TF”), fraud, or other criminal conduct.
1. PURPOSE OF THIS POLICY
1.1. The purpose of this Policy is to ensure that We comply with the rules and regulations set out in the PCMLTFA. By implementing this Policy, We aim to:
1.1.1. Protect the integrity and stability of the global financial system.
1.1.2. Ensure full compliance with all relevant legal and regulatory requirements.
1.1.3. Safeguard the Company from being exploited for ML/TF purposes.
1.1.4. Promote a culture of transparency and accountability within the Company.
1.1.5. Ensure all employees, Clients and stakeholders understand their responsibilities and the importance of adhering to these standards.
2. ACCOUNTABILITY
2.1. The Company is currently registered in Canada under company number 2027786017, which permits it to offer services involving virtual assets in accordance with applicable regulatory requirements and also being in the process of preparing to obtain an Money Services Business (hereinafter referred to as the “MSB”) authorization under the PCMLTFA.
3. RISK-BASED APPROACH
3.1. We maintain a risk-based approach to AML/CTF compliance, classifying Clients and transactions based on risk indicators such as:
3.1.1. Client profile (individual vs. legal entity);
3.1.2. Jurisdiction of origin;
3.1.3. Nature and volume of transactions;
3.1.4. Use of intermediaries or third-party instructions.
3.2. The Company carries out risk assessment for all Clients during the establishment of business relations and application of due diligence (hereinafter referred to as the “CDD”) measures. The following criteria are taken into account when assessing risks:
3.2.1. Client-related risks;
3.2.2. product, service, and transaction risks;
3.2.3. geographical and jurisdictional risks;
3.2.4. communication, intermediary, and delivery channel risks.
3.3. Based on the risk assessment, Clients may be assigned:
3.3.1. low risk;
3.3.2. medium risk;
3.3.3. high risk;
3.3.4. prohibited.
3.4. High-risk Clients or transactions may require enhanced due diligence (hereinafter referred to as the “EDD”), additional documentation, or managerial approval before execution.
3.5. Type of Clients. The Сompany serves 2 types of Clients:
3.5.1. Individual Clients – Individuals who use the Company’s Services to receive, manage, and efficiently utilize value through crypto-asset and fiat solutions.
3.5.2. Corporate Clients – сompanies that use the Company’s Services to conduct their operations and execute transactions involving crypto-assets..
3.6. Any changes to Client services will be reflected in updates to the Company’s policies and, where applicable, on the Company’s official social media platforms, and will be communicated to Clients without delay.
3.7. Know Your Customer (hereinafter referred to as the “KYC”) and Know Your Business (hereinafter referred to as the “KYB”). The Company implements KYC and KYB procedures to ensure the identification, verification, and ongoing monitoring of its Clients. These procedures are conducted in accordance with applicable AML/CTF laws of Canada and relevant international standards (e.g. FATF Recommendations).
3.8. Prior to any transaction, We implement full KYC procedures.
3.9. We reserve the right to request additional information, suspend accounts, or decline any transaction at the Company’s sole discretion.
3.10. The Company utilizes specialized automated software solutions, supported by manual review, to guarantee the accuracy and reliability of the verification process, improve operational efficiency, and enhance compliance with regulatory requirements.
3.11. The Company uses the services of such a trusted partner as Allpass.ai. Allpass.ai is a regulated solution provider that offers end-to-end identity verification, onboarding orchestration, and transaction risk monitoring tailored to the requirements of regulated industries, including crypto-assets. The platform is used to ensure that the identification and verification of Clients is conducted remotely, but with a level of reliability equivalent to in-person procedure.
3.13. However, the Company reserves the right to conduct KYC and KYB procedures manually when additional checks are needed, particularly in complex, high-risk, or unusual cases, or where automated methods do not provide sufficient verification assurance.
4. KYC FOR INDIVIDUAL CLIENTS
4.1. For individual Clients, the Company may collect and verify the following information:
- Full name;
- Birth number; and if not assigned, the Client’s date of birth;
- Address of permanent residence or other residence;
- Client’s nationality;
- Number and type of ID or passport, the State or, where applicable, the authority which issued the ID or passport and the period of its validity;
- Telephone number;
- Email address;
- Client’s confirmation that the Client is not a PEP;
- Information about the purpose of the business relationship that is collected in the Questionnaire;
- Type of the intended transaction;
- Total transaction value;
- Clients source of wealth general information;
4.2. A KYC questionnaire that will be sent to the Client for completion, capturing relevant personal, occupational, and transactional information to support the risk assessment process;
4.3. The Company reserves the right to request additional information, including but not limited to, documentation regarding the source of funds and source of wealth to properly verify the Client as part of the AML/CTF procedures.
5. KYB FOR CORPORATE CLIENTS
5.1. For corporate Clients , the Company may collect and verify the following information:
5.1.1. Details of representative of the legal entity:
- Full name, including title and any middle names;
- Citizenship;
- Date of birth and place of birth;
- Passport or other valid government-issued identity document;
- Residential address details;
- Proof of residential address (e.g., recent utility bill not older than 3 months);
- Telephone number and email address;
- Authority to represent the entity (e.g., Board Resolution, Power of Attorney);
- Liveness check (biometric verification);
- Confirmation that the person does not have a PEP status.
5.1.2. Details of each director:
- Full name, including title and any middle names;
- Citizenship;
- Date and place of birth;
- Residential address details;
- Telephone number;
- Email address;
- A clear copy of a valid document confirming the identity of the person (e.g., passport, national ID card, or driver’s license);
- Confirmation that the person is not a politically exposed person or a close relative of a politically exposed person;
- A mandatory liveness check is required for the CEO (General Manager or President of the Management Board);
- The Сompany reserves the right to request a liveness check from any director if deemed necessary following the directors’ document review.
5.1.3. Details of each ultimate beneficial owner ( hereinafter referred to as the “UBO”):
- The Company shall identify all natural persons who ultimately own or control the Client. This includes, but is not limited to:
- individuals directly or indirectly holding ≥ twenty-five (25)% of shares or voting rights;
- individuals exercising control via other means (contractual, voting, management);
- senior managing officials, where no UBO can be identified based on ownership or control.
- The following information must be obtained for each UBO:
- all data as for for individuals; and
- % of holding.
5.1.4. Details of company data:
- Full legal name;
- Identification number;
- Organizational form;
- Address of the registered office;
- Address of the actual place of business activity, if different from the registered office address;
- Designation of the official register or other official record in which the legal entity is entered;
- Entry number in this register or record;
- Canada tax identification number (if applicable);
- in the case of a lack of the tax identification number:
- the state of registration;
- the name of the relevant commercial register;
- the date of registration.
- Ownership and control structure of the legal person, including direct and indirect ownership;
- Source funds or wealth;
- Website (if applicable);
- License availability (if applicable);
- AML/CFT policies (if applicable).
- Incorporation documents (proof of the legal existence of the legal entity):
- Certificate of Incorporation; or
- Articles of Association; or
- Memorandum of Association; or
- Extract from the register.
- Proof of the legal entity’s registered address and office: A recent utility bill (e.g., electricity, water, phone), dated within the last 3 months.
5.2. The Company may request documents confirming the source of funds and source of wealth based on the declared turnover or actual transaction activity. Supporting documentation should correspond to the nature of the business and declared income. Acceptable documents may include contracts, bank statements, invoices, or other records clearly demonstrating the lawful origin of funds, depending on the specific case.
5.3. A corporate KYB questionnaire will be provided to the Client to collect structured information on legal structure, economic activity, and intended transactional behavior.
6. RETENTION PERIOD
6.1. The Company retains Client-related data for no less than five (5) years after the end of the business relationship. This retention period may be extended to address regulatory requests, ongoing investigations, or changes in applicable laws. Once the retention period has expired, the data is securely destroyed under management supervision, unless further retention is required by law.
7. IMPLEMENTATION OF SANCTIONS
7.1. The Company strictly adheres to international and national sanctions regimes to prevent the use of Its Services for activities that could support ML, TF, or other forms of illicit conduct.
7.2. The Company does not provide services to individuals and entities listed on sanctions registers maintained by the United Nations (UN), the European Union (EU), the U.S. Department of the Treasury (OFAC) or Canada. This applies to both individuals and legal entities included in the official sanctions lists of these bodies. Persons whose citizenship or country of permanent residence is associated with territories considered to pose a high risk of AML/CTF non-compliance or subject to geopolitical restrictions are also banned.
7.3. In addition to sanctions restrictions, the Company does not provide services, whether directly or indirectly, to individuals or entities located in, incorporated in, or otherwise connected to the following jurisdictions / territories: Abkhazia, Afghanistan, Azerbaijan, Bangladesh, Belarus, Bolivia, Burundi, Cambodia, Central African Republic, China, Crimea (region of Ukraine), Cuba, Democratic Republic of the Congo, Eritrea, Equatorial Guinea, Federal Republic of Ambazonia, Gabon, Guatemala, Guinea, Guinea-Bissau, Haiti, Honduras, Iran, Iraq, Kosovo, Kyrgyzstan, Lebanon, Libya, Madagascar, Mali, Myanmar (Burma), Non-government controlled areas of region of Donetsk (region of Ukraine), Non-government controlled areas of region of Kherson (region of Ukraine), Non-government controlled areas of region of Luhansk (region of Ukraine), Non-government controlled areas of region of Zaporizhzhia (region of Ukraine), Nicaragua, Niger, North Korea (DPRK), Pakistan, Palestine, Paraguay, Republic of Artsakh, Russia, Somalia, South Ossetia, South Sudan, Sudan, Syria, Tajikistan, Transnistria, Tunisia, Turkmenistan, Venezuela, Yemen, Zimbabwe and other countries and jurisdictions, where these services can not be provided by legislation countries.
7.4 The Company reserves the right to deny services to any individual or organization whose activities, funding sources, or associations with third parties raise reasonable concerns about potential breaches of AML regulations.
8. REFUSAL TO THE BUSINESS RELATIONSHIP
8.1. The Company may decline to establish or continue a business relationship where a Client is subject to sanctions, suspected of involvement in money laundering or terrorist financing, or where the Client’s risk profile exceeds thresholds established by the Company or applicable law. The Company may also refuse, suspend, or terminate a transaction if the Client fails to provide required documentation, submits false or incomplete information, withholds details regarding ultimate beneficial owners, or otherwise attempts to circumvent disclosure requirements.
8.2. In such circumstances, the Company, acting as a responsible entity, may withhold the provision of services and, where appropriate, report the identified risks to the Financial Transactions and Reports Analysis Centre of Canada (hereinafter referred to as the “FINTRAC”). In addition, if a Client refuses or unjustifiably delays the provision of requested information, the Company will evaluate the matter based on the Client’s risk profile and, where warranted, may terminate the business relationship or refuse to execute financial transactions.
9. REPORTING AND COOPERATION
9.1. Unusual business transactions are reported immediately to the FINTRAC. We also fully cooperate with:
9.1.1. National regulators,
9.1.2. Financial supervisory authorities,
9.1.3. Law enforcement agencies across jurisdictions,
9.1.4. Relevant courts.
10. TRAINING AND INTERNAL CONTROLS
10.1. The Company prioritises employee training and strict internal controls to ensure compliance with regulatory requirements and to protect the interests of our Clients.
10.2. The Company’s employees undergo regular training in:
10.2.1. AML legislation,
10.2.2. Sanctions compliance,
10.2.3. Fraud prevention,
10.2.4. Blockchain-based risk analysis.
11. OUR CONTACTS
11.1. If you have any comments or questions with respect to this Policy please feel free to contact Us via e-mail: officialaxisprotocol@gmail.com.
12. FINAL SECTION
12.1. This Policy is reviewed no less than annually to maintain its relevance, accuracy, and effectiveness, taking into account changes in applicable legislation, regulatory guidance, and business practices.
12.2. The Company may perform additional reviews when prompted by legislative amendments, regulatory observations, operational changes, or internal risk evaluations.
12.3. Any updates to this Policy will be communicated to Clients through the Company’s official communication channels, including, without limitation, the Platform, email notifications, and Client account dashboards, where applicable.
12.4. Beyond meeting legal requirements, the Company is committed to transparency and trust and encourages Clients to review this Policy periodically to remain informed of their rights, obligations, and the Company’s compliance processes.