Anti-Money Laundering (AML) Policy

To prevent money laundering, Orynvia Wealth implements a strict Know Your Customer (KYC) program. Before accessing full trading features or withdrawing funds, users must provide proof of identity, proof of address, and source of funds documents when requested.

• Proof of Identity: A valid government-issued ID, such as a passport, national ID, or driver's license. Copies must be clear, unexpired, and include a photograph and signature.
• Proof of Address: A utility bill, bank statement, or government-issued tax document dated within the last 3 months. PO boxes are not accepted.
• Source of Funds: For deposits exceeding $10,000 equivalent, or where risk indicators exist, supporting documents such as pay stubs, tax returns, sale of assets, or inheritance records may be required.

We reserve the right to refuse service to any individual or entity who fails to provide sufficient identification or who provides false or misleading information.

Orynvia Wealth applies a risk-based approach to customer onboarding and monitoring. Customers are categorized into Low, Medium, or High risk based on geographic location, transaction volume and velocity, occupational exposure, and business structure.

Enhanced Due Diligence (EDD) is mandatory for all high-risk customers and includes additional proof of wealth and source of funds, a minimum account history of 6 months before certain withdrawal limits are lifted, monthly manual review of transaction activity by the Compliance Officer, and senior management approval before account opening.

Politically Exposed Persons (PEPs): Any individual identified as a foreign or domestic PEP, including family members or close associates, must undergo EDD regardless of transaction size.

Orynvia Wealth employs automated transaction monitoring systems, including blockchain analytics for crypto assets, to detect suspicious patterns.

• Unusual structuring: Multiple transactions just below $10,000 or another reporting threshold within a 24-hour period.
• Rapid movement: Deposits followed immediately by withdrawals to unrelated third-party wallets or accounts with no trading activity.
• Geographic mismatch: Logins or transactions originating from high-risk jurisdictions while the user's registered address is in a low-risk country.
• Unusual growth: Sudden large deposits inconsistent with the user's known financial profile or prior activity.
• Peer-to-peer risks: Frequent receipt of funds from non-exchange addresses with no clear economic purpose.

If suspicious activity is detected, Orynvia Wealth is legally obligated to file a Suspicious Activity Report (SAR) with relevant Financial Intelligence Units without notifying the user. Filing a SAR is protected under safe harbor provisions, and no employee or contractor may disclose the existence of a SAR.

Orynvia Wealth screens all users against international sanctions lists, including those maintained by the United Nations Security Council, OFAC, the EU External Action Service, and UK HM Treasury.

We do not open accounts or process transactions for individuals or entities located in sanctioned jurisdictions such as North Korea, Iran, Syria, the Crimea region, Cuba, or any jurisdiction subject to comprehensive sanctions. We also apply heightened scrutiny to transactions involving jurisdictions identified by the Financial Action Task Force as having strategic AML deficiencies.

In accordance with global financial regulations, Orynvia Wealth maintains records of all customer identification documents, transaction data, SAR filings, internal AML correspondence, and approval decisions.

These records are stored in encrypted, access-controlled systems for a minimum period of five years after the account is closed, or longer if required by local law. Records may be provided to competent authorities upon a valid legal request or court order.

All employees, contractors, and officers receive mandatory AML/CTF training upon hire and annually thereafter.

• Upon hire: foundational AML principles, red flags, and reporting obligations.
• Annually thereafter: updated regulations, case studies, and emerging typologies.
• Role-specific training: guidance for customer support, compliance, and engineering teams on how to escalate suspicious activity in ticket systems.

Training completion is tracked, and employees who fail to complete training are restricted from handling customer accounts or transactions.

Orynvia Wealth engages an external, independent auditor at least once every 12 months to review the effectiveness of AML/CTF policies, test KYC files and transactions, assess monitoring performance, and provide a written report to senior management and, where required, to regulatory authorities.

Remedial actions from audit findings are tracked and implemented within 60 days.

The following activities are strictly prohibited and may result in immediate account termination and reporting to FIUs:

• Using the platform to transmit funds derived from or intended for illegal activities.
• Using anonymous cryptocurrencies such as Monero or Zcash with shielded addresses without prior approval.
• Accessing the platform via VPN or Tor from a sanctioned jurisdiction.
• Creating multiple accounts to circumvent KYC or transaction limits.

Orynvia Wealth reserves the right to suspend withdrawals pending investigation of suspicious activity for a period not exceeding 10 business days, or longer if required by law.

All AML-related data is processed in accordance with applicable privacy laws, including GDPR and CCPA.

Customer information collected for KYC purposes is used only for AML/CTF compliance and fraud prevention, and is never sold or shared for marketing purposes. Access to AML data is limited to the Compliance Officer, internal audit team, and designated legal staff, and all access is logged and audited.

Any employee, customer, or third party who suspects money laundering or terrorist financing on the Orynvia Wealth platform must report it immediately to our Compliance Officer. Anonymous reports are accepted.

• Email: compliance@orynviawealth.com
• Secure reporting portal: internal link for authenticated users
• Urgent or law enforcement matters: use encrypted communication with the PGP key available upon request

This policy is reviewed annually or whenever there is a material change in regulations, business operations, or risk environment. All changes are communicated to registered users via email and platform notification.