KYC & AML Policy

1. Purpose

CAPIOV Ltd is committed to preventing money laundering, terrorist financing and fraud. We apply identity and business checks (known as Know Your Customer, or KYC) and monitor activity in line with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and related UK law, and we work with regulated payment partners who apply their own checks.

2. Verification (KYC)

Depending on what you do on the platform, we may ask you to verify your identity or your business before you can receive payouts, trade in bulk, or transact above certain thresholds. Verification is carried out with our verification partners (see our Privacy Policy) and may include confirming your identity documents, business registration and ownership. We apply a risk-based, tiered approach: lighter checks for low-risk activity and enhanced checks where the risk is higher.

3. Ongoing monitoring

ILEIQ Market monitors activity for signs of financial crime, including:

• unusual, inconsistent or unusually large transactions;
• attempts to disguise the source or destination of funds;
• self-dealing, structuring, or other manipulation; and
• use of the platform that does not match a stated business purpose.

4. When we may freeze or refuse funds

We may pause, freeze or refuse a transaction or payout, and hold funds, where:

• required verification is incomplete or checks are pending;
• we reasonably suspect money laundering, fraud or other crime;
• a sanctions or watchlist match needs to be resolved; or
• we are required to by law or by a competent authority.

Where the law permits, we will tell you what we need to release funds. In some cases the law prevents us from explaining why a matter is delayed.

5. Reporting

Where we are required to, we report suspicious activity to the National Crime Agency (NCA) through a Suspicious Activity Report, and cooperate with law enforcement and regulators. The law can prohibit us from telling you that a report has been made ("tipping off"), so there may be occasions where we cannot give a full explanation.

6. Your responsibilities

You must:

• provide accurate, current verification information when asked;
• use the platform only for lawful, genuine transactions; and
• not help anyone disguise the origin of funds or evade these checks.

7. Your rights and data

We handle verification data in line with our Privacy Policy. You can ask us about the personal data we hold and exercise your data-protection rights, subject to the legal limits that apply to financial-crime records. We keep identity and AML records for the period the law requires (generally five years after our relationship with you ends).

8. Contact

Questions about verification or this policy? Contact us at support@ileiq.com. This policy is governed by the law of England and Wales.