Anti Money Laundering & Anti-Fraud Policy.

Flixsend Ltd ("Flixsend", "we", "our" or "us") is committed to maintaining a secure and responsible digital transaction environment. We recognise the importance of preventing our platform from being used for money laundering, terrorist financing, fraud and other unlawful activities.

This Anti-Money Laundering and Anti-Fraud Policy ("Policy") explains our approach to identifying, assessing and reducing financial crime risks associated with activities conducted through our platform.

This Policy applies to users of Flixsend's services and, where relevant, personnel, service providers and business partners involved in supporting those services.

The purpose of this Policy is to establish principles and safeguards designed to reduce the risk of financial crime across Flixsend's services.

Our approach is intended to:

• Prevent the use of our platform for money laundering and terrorist financing.
• Reduce fraudulent transactions, account abuse and identity theft.
• Promote appropriate customer identification and verification.
• Identify unusual or potentially suspicious transaction patterns.
• Protect users, business partners and the integrity of the platform.
• Support compliance with applicable laws and relevant partner requirements.

Flixsend aims to operate with integrity, transparency and appropriate safeguards against financial crime. We seek to apply risk-based controls that are proportionate to the nature of our services, the transactions supported and the jurisdictions involved.

Our controls may be reviewed and adjusted as our services, risks, applicable legal requirements and financial partner requirements evolve.

Money laundering involves concealing or disguising the origin, ownership, movement or destination of funds obtained through unlawful activities. Flixsend does not permit its platform to be used to process or facilitate proceeds of crime.

Depending on the service and applicable requirements, our AML controls may include:

• Collecting and verifying user identity information.
• Assessing transaction activity for unusual or inconsistent patterns.
• Applying transaction limits and additional verification where appropriate.
• Reviewing transactions that present elevated financial crime risks.
• Restricting activity where there are reasonable concerns about unlawful conduct.
• Escalating suspicious matters and making reports where legally required.

Flixsend prohibits the use of its services to raise, move, conceal or distribute funds or other resources for terrorist organisations, terrorist activities or individuals involved in terrorism.

We may use risk-based screening, transaction reviews, account assessments and other appropriate controls to identify potential terrorist financing risks.

Where necessary and permitted or required by law, we may restrict activity and cooperate with competent authorities or relevant financial partners.

Flixsend may require users to provide identity and other verification information before accessing certain features or completing certain transactions.

Depending on the service, jurisdiction and risk level, verification may involve:

• Full legal name and date of birth.
• Valid government-issued identification.
• Phone number and email verification.
• Residential address or other relevant contact information.
• Photographs, facial verification or liveness checks.
• Additional information reasonably required to understand a transaction or account.

Users must provide accurate, complete and genuine information. Providing false, misleading, altered or stolen identity documents is prohibited.

Verification requirements may vary depending on the services used, transaction limits, risk assessments and applicable legal or financial partner obligations.

Certain users, transactions or business relationships may present higher financial crime risks and may require additional checks.

Enhanced due diligence may include:

• Requesting additional identity or address documentation.
• Seeking information about the source of funds or source of wealth.
• Reviewing the purpose and expected nature of transactions.
• Conducting additional checks on relevant individuals or entities.
• Increasing the frequency or depth of transaction monitoring.

Additional checks may also apply to politically exposed persons (PEPs), persons associated with elevated-risk jurisdictions or other relationships identified as higher risk under applicable standards.

Flixsend may review transaction activity to identify unusual, inconsistent or potentially suspicious behaviour. Monitoring measures are designed to help detect activity that may indicate fraud, money laundering, account compromise or other prohibited conduct.

Examples of activity that may receive additional review include:

• Transactions inconsistent with a user's known or expected activity.
• Unusual transaction frequency, volume or patterns.
• Repeated transactions structured to avoid applicable limits or checks.
• Multiple accounts displaying connected or coordinated suspicious behaviour.
• Transactions involving suspicious counterparties or payment details.
• Attempts to move funds through accounts without a legitimate apparent purpose.

Monitoring does not mean that every unusual transaction is unlawful. Reviews are conducted to assess relevant circumstances and determine whether further action is appropriate.

Flixsend seeks to prevent prohibited transactions involving individuals, entities, organisations or jurisdictions subject to applicable financial sanctions or restrictions.

Where relevant to our services and legal obligations, we or our service providers may screen users, counterparties and transactions against applicable sanctions lists and restricted-party information.

Potential matches may be reviewed before a decision is made. Where a restriction or prohibition applies, Flixsend may decline, suspend, block or otherwise restrict the relevant activity as permitted or required by law.

Flixsend works to reduce fraudulent activity and protect users against deception, unauthorised access, payment abuse and other forms of fraud.

Fraud prevention measures may include:

• Account verification and authentication checks.
• Monitoring for unusual login and account access behaviour.
• Reviewing suspicious payment and transaction activity.
• Detecting duplicate, impersonated or misleading accounts.
• Investigating reports of scams, chargebacks and unauthorised transactions.
• Applying transaction holds or additional checks where appropriate.

Common Forms of Prohibited Fraud

• Identity theft and impersonation.
• Phishing, social engineering and account takeover.
• Use of stolen payment credentials or compromised accounts.
• Fake payment confirmations and fabricated transaction evidence.
• Chargeback abuse and deliberate payment disputes based on false claims.
• Fraudulent offers, misleading listings and dishonest P2P trading practices.

Users must not use Flixsend to conduct, facilitate, conceal or benefit from unlawful or fraudulent activity.

Prohibited activities include, but are not limited to:

• Money laundering or handling proceeds of crime.
• Terrorist financing or supporting sanctioned activities.
• Fraud, scams, deception and financial misrepresentation.
• Using stolen, unauthorised or falsified identities.
• Operating accounts on behalf of undisclosed third parties for unlawful purposes.
• Using Flixsend to receive or transfer funds connected to criminal activity.
• Attempting to bypass verification, transaction limits or security controls.
• Creating multiple accounts to evade restrictions or investigations.
• Trading in prohibited goods, services or other unlawful transactions.

Where activity raises reasonable concerns, Flixsend may conduct an internal review, request additional information or escalate the matter through appropriate compliance channels.

Where required by applicable law or relevant contractual obligations, Flixsend may report suspicious activity to the appropriate authorities, regulators or financial partners.

We may be legally restricted from informing a user that a suspicious activity report or related investigation has been made or is being considered. Nothing in this Policy requires Flixsend to disclose confidential investigative information where disclosure is prohibited.

Flixsend may take appropriate action where an account, transaction or user relationship presents a suspected risk of fraud, money laundering, terrorist financing, sanctions violations or other prohibited activity.

Depending on the circumstances and applicable law, actions may include:

• Requesting further information or verification.
• Delaying or declining a transaction.
• Restricting access to specific platform features.
• Temporarily suspending an account while a review is conducted.
• Closing an account or ending a business relationship.
• Preserving relevant information and cooperating with authorised investigations.

Any restriction, hold or decision concerning funds will be handled subject to applicable law, relevant payment partner requirements and any applicable legal process.

Flixsend may work with payment providers, technology providers, verification services, financial institutions and other third parties to support the operation and security of its services.

Depending on their role, these providers may carry out identity checks, payment processing, fraud screening, transaction reviews or other security and compliance-related activities.

Their services may be subject to separate terms, privacy notices, legal obligations and compliance procedures. Flixsend may share relevant information with these providers where necessary and legally permitted to deliver services, prevent fraud or meet applicable obligations.

Flixsend may maintain records relating to user verification, transactions, account activity, compliance reviews and relevant communications for legitimate operational, security and legal purposes.

Records will be retained for the period required by applicable law, regulatory obligations, legitimate business needs or relevant partner requirements.

Access to such records is subject to appropriate controls and applicable data protection requirements.

Flixsend recognises that effective financial crime prevention requires appropriate internal awareness and controls.

Where applicable, personnel involved in relevant operational, support, security or compliance activities may receive guidance on identifying suspicious behaviour, escalating concerns, protecting confidential information and following relevant procedures.

Internal procedures may be reviewed and improved as the platform and its risk environment develop.

Information collected for identity verification, fraud prevention, transaction monitoring or compliance purposes is handled in accordance with applicable data protection requirements and Flixsend's Privacy Policy.

We seek to limit access to sensitive information to authorised personnel and service providers who need it for legitimate operational, security or legal purposes.

Information may be disclosed to competent authorities, regulators, financial partners or other relevant parties where disclosure is legally required or otherwise permitted.

For more information about how personal information is handled, please read our Privacy Policy.

Flixsend may cooperate with law enforcement agencies, regulators, courts, financial institutions and other competent authorities in connection with lawful requests and investigations.

Any cooperation or disclosure will be handled in accordance with applicable laws, legal processes and relevant confidentiality obligations.

Every user has a responsibility to use Flixsend honestly, lawfully and responsibly.

By using our services, users agree to:

• Provide accurate and truthful identity and account information.
• Use only accounts and payment methods they are authorised to use.
• Keep login credentials and authentication details secure.
• Provide genuine transaction information and evidence when requested.
• Respond reasonably to legitimate verification requests.
• Report suspected fraud, account compromise or suspicious activity.
• Refrain from facilitating unlawful transactions or helping others evade controls.

Users must not attempt to interfere with, bypass or undermine Flixsend's security and compliance measures.

Flixsend may update this Policy from time to time to reflect changes in applicable laws, regulatory expectations, industry practices, platform features or our internal risk controls.

Updated versions will be published on this page with a revised effective or last-updated date.

Continued use of our services after an update takes effect will be subject to the updated Policy, to the extent permitted by applicable law.

If you have questions about this AML and Anti-Fraud Policy, need to report suspected fraudulent activity, or have concerns about a transaction or account, please contact Flixsend through our available support channels.