AML / KYC Policy

Last updated: 19 May 2026 · Anti-Money-Laundering & Know-Your-Customer alignment

A1x takes anti-money-laundering ("AML") and know-your-customer ("KYC") matters seriously. This Policy describes our approach. A1x is not itself a regulated financial-services provider; we are a software-services vendor. However, because we accept cryptocurrency payments via a regulated processor, we align our practices with industry expectations for AML / KYC.

1. Payment processing & regulated processor

All cryptocurrency payments to A1x are processed exclusively through CryptoCloud OÜ, an EU-licensed virtual-asset service provider operating under Estonian Financial Intelligence Unit supervision. CryptoCloud operates its own AML / KYC procedures on the payment side, including transaction monitoring, sanctions screening, and risk-based reviews of high-value payments.

A1x does not:

• Accept cryptocurrency payments outside the CryptoCloud gateway;
• Hold customer cryptocurrency balances at any time;
• Provide wallet, exchange, custody, or investment services;
• Mix, tumble, or otherwise obscure cryptocurrency transactions;
• Accept anonymous payments — every payment is tied to a specific invoice, which is tied to a specific Customer record.

2. Customer due diligence

Before issuing the first invoice, A1x records the Customer's:

• Working contact email address (verified by a confirmation message);
• Customer / business name;
• Stated purpose of the engagement;
• Country of operation (informally, for jurisdictional risk-assessment).

For larger engagements (above a published threshold), or where any of the risk indicators in section 4 are present, A1x reserves the right to request additional verification — for example, a government-issued ID, proof of business registration, or proof of address — before accepting the engagement. Documents provided for verification are encrypted at rest and deleted once the verification decision has been recorded.

3. Sanctions screening

A1x will not knowingly do business with persons or entities subject to UK, EU, or UN sanctions. Customers based in, or operating from, jurisdictions subject to comprehensive sanctions are not accepted. CryptoCloud's payment-side sanctions screening provides an additional layer of detection on every transaction.

4. Risk indicators

A1x flags engagements for additional review where any of the following are present:

• Refusal or inability to provide a working contact email or business identity;
• Payment requests from third parties (we only accept payment from the contracting Customer);
• Payments structured to fall just below the verification threshold;
• Engagements where the stated purpose appears inconsistent with the level of activity;
• Requests to disable standard logging or auditability features of the panel software;
• Connection from sanctioned jurisdictions or use of anonymising IP infrastructure to access the Builder Portal in combination with any other risk indicator.

The presence of one or more indicators does not automatically mean an engagement is rejected, but it triggers human review by A1x staff before service provisioning continues.

5. Suspicious-activity reporting

Where A1x identifies activity that gives rise to a reasonable suspicion of money-laundering, terrorism financing, or other financial crime, we will: (a) suspend the affected services; (b) preserve relevant records; and (c) report the activity to the appropriate UK authority (the National Crime Agency, or any other body required by law). We will not "tip off" the affected party that a report has been made.

6. Record retention

AML-relevant records (Customer due-diligence files, invoice metadata, payment confirmations, internal risk-review notes) are retained for the period required by UK law (currently 5 years from the end of the business relationship). After that period, they are securely destroyed.

7. Cooperation with authorities

A1x cooperates with any lawful request from a competent UK authority (court, regulator, or law-enforcement) for information about a Customer or transaction, subject to verifying the validity of the request.

8. Contact

AML / compliance queries: support@a1x-panels.com — subject line "Compliance".