Anti-Money Laundering Policy

1. Our Commitment

New Funds Club ("NFC") maintains a zero-tolerance stance toward money laundering, terrorist financing, and any attempt to use the Platform to process funds of illicit origin.

We implement a risk-based AML framework with controls calibrated to the risk profile of our members, transactions, and geographies. This policy applies to all members, administrators, and any third parties acting on behalf of NFC.

2. Know Your Customer (KYC)

All members must complete identity verification before deposits, contract activations, or withdrawals are permitted. KYC requirements include:

Standard Verification

• Full legal name, date of birth, and country of residence;
• Government-issued photo ID (passport, national ID card, or driver's licence);
• Proof of address dated within the last 3 months (utility bill, bank statement, or official government letter).

Enhanced Due Diligence (EDD)

Enhanced verification is required for members who:

• Transact above defined threshold amounts;
• Are identified as Politically Exposed Persons (PEPs) or their close associates;
• Originate from jurisdictions assessed as high-risk;
• Present unusual transaction patterns triggering risk flags.

EDD may require source-of-funds documentation, additional identification, or enhanced ongoing monitoring.

3. Deposit Controls

All deposits are reviewed by NFC administrators before being credited. Deposits may be declined or held pending investigation if:

• The source of funds cannot be verified;
• The transaction originates from a sanctioned address or jurisdiction;
• The deposit is inconsistent with the member's stated profile or prior activity;
• The deposit amount is structured to avoid reporting thresholds (structuring);
• The wallet address has been flagged in blockchain analytics tools.

Only deposits from accounts or wallets in the member's own name will ordinarily be accepted. Third-party deposits require prior written approval.

4. Transaction Monitoring

NFC employs ongoing monitoring of all financial activity on the Platform, including:

• Deposits, withdrawals, and contract activations;
• Unusual patterns such as rapid cycling of funds, structuring, or unexplained large transactions;
• Geolocation inconsistencies or access from high-risk jurisdictions;
• Changes to linked wallet addresses or withdrawal destinations.

All transactions and administrative actions are recorded in an immutable audit log.

5. Reporting Obligations

Where NFC identifies activity that gives rise to suspicion of money laundering or terrorist financing, we are obligated to file a Suspicious Activity Report (SAR) or equivalent with the relevant financial intelligence unit.

We are prohibited from "tipping off" — informing a member or third party that a SAR has been filed or is under consideration. Accounts under investigation may be frozen without prior notice.

6. PEP & Sanctions Screening

All members are screened against:

• OFAC (US Treasury) Specially Designated Nationals list;
• EU consolidated sanctions list;
• UN Security Council sanctions list;
• Domestic PEP databases.

Matches trigger enhanced due diligence. Confirmed hits from sanctions lists result in immediate account suspension and reporting to authorities.

7. Record Keeping

In accordance with applicable AML regulations, NFC retains:

• KYC documentation for a minimum of 5 years from account closure;
• Transaction records for a minimum of 5 years from the date of the transaction;
• Audit logs and administrative records for a minimum of 3 years.

8. Non-Compliance & Consequences

Any member found to be using the Platform to launder money or finance illegal activities will have their account immediately terminated. Funds on the account will be frozen pending investigation and, where legally required, reported to and surrendered to the relevant authorities.

NFC reserves the right to report suspicious activity regardless of whether the full legal threshold for mandatory reporting has been reached.

For AML-related enquiries, contact support@nfcapital.com.