AML and CTF Policy

This draft policy sets out how THEKINGDELLY LTD intends to prevent its platform from being used for money laundering, terrorist financing, sanctions evasion or fraud.

It is a working draft prepared for legal and compliance review. It does not assert that KingXchange holds any licence, authorisation or regulatory approval, and no such claim should be inferred from its publication.

KingXchange does not currently accept payments, hold customer funds, execute conversions or maintain customer balances. No identity verification provider is connected yet.

Before any of those activities begin, a verification provider must be appointed, the policy must be approved, and the operating arrangements must be reviewed against the requirements of each market served.

Customers, corridors and products will be assessed by risk. Higher-risk situations — for example unusual transaction patterns, higher-risk jurisdictions, or complex ownership structures — will require enhanced measures.

Controls will be proportionate to the risk identified, and lower-risk customers will follow standard due diligence.

• Individual customers: identity, date of birth, address, and verification of the identity document provided.
• Business customers: company registration details, nature of business, and identification of beneficial owners and those controlling the account.
• All customers: the purpose of the relationship, expected transaction activity, and where required the source of funds and source of wealth.
• Enhanced measures: additional evidence, senior approval and closer monitoring where the risk assessment requires it.

Customers and beneficial owners will be screened against politically exposed person designations and against applicable sanctions lists, including United Nations, Nigerian, United Kingdom, European Union and United States lists where relevant to the service.

A confirmed match will result in the relationship being declined, suspended or reported as required by law.

Activity will be monitored against the expected profile of the customer, with alerts reviewed and documented. Monitoring rules will be tuned before live operation and reviewed periodically.

Where we know or suspect that funds are the proceeds of crime or are linked to terrorist financing, we will report to the appropriate authority: the Nigerian Financial Intelligence Unit in Nigeria, the National Crime Agency in the United Kingdom, or the financial intelligence unit of the relevant EU member state.

We will not disclose to the customer that a report has been made where the law prohibits it.

Identity records, verification results, transaction records and decisions will be retained for the period required by applicable law, and will be available to the relevant authorities on request.

A named individual will be responsible for this policy, supported by documented procedures and periodic training for anyone handling customer records.

Nigeria: the Money Laundering (Prevention and Prohibition) Act 2022 and related guidance, together with the securities and digital asset rules applicable to the activity once confirmed.

United Kingdom: the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, to the extent the activity falls within scope.

European Union: the anti-money-laundering directives and the Markets in Crypto-Assets Regulation, as implemented in the member states served.

These references are indicative. Counsel must confirm which obligations actually apply to the operating model before any service is enabled.

This policy will be reviewed as providers are appointed and as the regulatory position is confirmed. Questions can be sent to thekingdellyltd@gmail.com.