Legal
AML Policy
Last updated: 2026.
1. Commitment to Compliance
Ultimo is committed to the highest standards of anti-money laundering (AML) and counter-terrorism financing (CTF) compliance. We maintain a comprehensive AML/CTF programme designed to prevent the Platform from being used to facilitate financial crime. This policy sets out the key principles and procedures that govern our compliance obligations. All users of the Platform must adhere to applicable AML/CTF laws and cooperate fully with our compliance processes.
2. Know Your Customer (KYC)
Before accessing certain features of the Platform, users are required to complete our identity verification (KYC) process. This involves providing government-issued identification documents, proof of address, and other information as required. The extent of information required may vary based on the level of activity on your account. We use third-party identity verification providers and may conduct verification against watchlists and sanctions databases. We reserve the right to refuse service or close accounts where KYC cannot be satisfactorily completed.
3. Customer Due Diligence
We apply risk-based customer due diligence (CDD) measures proportionate to the risk presented by each user. Standard due diligence applies to most users. Enhanced due diligence (EDD) is applied to higher-risk customers, including politically exposed persons (PEPs), users from higher-risk jurisdictions, and accounts with high transaction volumes or unusual activity patterns. We conduct ongoing monitoring of accounts to ensure that activity is consistent with our knowledge of the customer.
4. Transaction Monitoring
We monitor all transactions conducted through the Platform for signs of suspicious activity. Our monitoring systems use automated rules and analytics to flag transactions that may be indicative of money laundering, terrorism financing, or other financial crime. This includes monitoring for structuring, rapid movement of funds, transactions involving high-risk jurisdictions, and activity inconsistent with a user's stated purpose. Blockchain analytics tools may be used to assess the risk of incoming and outgoing cryptocurrency transfers.
5. Suspicious Activity Reporting
Where we identify activity that we know, suspect, or have reasonable grounds to suspect may be related to money laundering or terrorist financing, we are required by law to file a Suspicious Activity Report (SAR) with the appropriate financial intelligence unit. We are prohibited by law from informing ("tipping off") the subject of a SAR that a report has been made. Our obligation to file SARs takes precedence over any duty of confidentiality to our users.
6. Sanctions Compliance
Ultimo does not provide services to individuals or entities that are subject to applicable sanctions programmes, including those maintained by the United Nations, the European Union, the United States Office of Foreign Assets Control (OFAC), and other relevant authorities. We screen all users and transactions against applicable sanctions lists. Accounts found to be associated with sanctioned individuals, entities, or jurisdictions will be immediately suspended and reported to the relevant authorities.
7. Prohibited Activities
The Platform must not be used to: launder the proceeds of crime; finance terrorism or proliferation of weapons of mass destruction; conduct transactions on behalf of sanctioned persons or entities; evade taxes or other legal obligations; facilitate fraud or other financial crime; or circumvent the AML/CTF controls of Ultimo or any other regulated entity. Any user found to be engaging in such activities will have their account suspended and the matter reported to the appropriate authorities.
8. Record Keeping
We maintain records of all customer identification information, transaction records, and AML/CTF compliance documentation for a minimum period as required by applicable law — typically five years from the end of the customer relationship or the completion of the transaction. These records are available for inspection by relevant regulatory authorities upon request.
9. Staff Training
All Ultimo employees who are involved in customer-facing activities or transaction processing receive regular training on AML/CTF obligations, red flags for suspicious activity, and the procedures for escalating concerns. Our compliance team oversees the AML/CTF programme and reports directly to senior management.
10. Policy Review
This AML Policy is reviewed and updated at least annually, or more frequently in response to changes in applicable law, regulation, or best practice. Users are encouraged to review this policy periodically. Questions about our AML/CTF compliance programme can be directed to our compliance team via the support channels listed on the Platform.
Disclaimer
DRAFT v1.0 — PENDING LEGAL REVIEW. This document is a working draft provided for transparency. Final, legally binding policies will be published following review by BVI counsel and compliance officers.