Anti-Money-Laundering & Know-Your-Customer Policy

IronXLedger Holdings Ltd. is committed to the prevention of money laundering, the financing of terrorism, the proliferation of weapons of mass destruction, and the evasion of international sanctions. This Policy describes, in summary form, the risk-based program (the "Program") implemented by IronXLedger to detect, deter, and report financial crime through the IronXLedger platform (the "Platform").

1. Regulatory Framework

The Program is designed to comply with the recommendations of the Financial Action Task Force, the European Union's anti-money-laundering directives, the United States Bank Secrecy Act and Office of Foreign Assets Control regulations, the United Kingdom's Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations, and any other framework applicable to the jurisdictions in which IronXLedger conducts business.

2. Customer Due Diligence

Prior to the establishment of any business relationship and on an ongoing basis, IronXLedger applies customer due-diligence ("CDD") measures proportionate to the assessed money-laundering and terrorist-financing risk of each Client relationship. Standard CDD includes verification of identity against an independent and reliable source, verification of residential address, identification of beneficial ownership in respect of legal-entity Clients, and screening against politically exposed person, sanctions, and adverse-media databases. Enhanced due diligence is applied to Clients, transactions, jurisdictions, and channels presenting elevated risk indicators.

3. Source-of-Funds and Source-of-Wealth

IronXLedger may, at any time and in its sole and unfettered discretion, request documentary evidence of the source of funds or source of wealth applied to the Platform. Failure to furnish satisfactory evidence within the period specified may result in the suspension of account functionality, the freezing of balances, the rejection of withdrawal instructions, and, where appropriate, the filing of a suspicious activity report with the relevant Financial Intelligence Unit.

4. Transaction Monitoring

All Platform activity is subject to continuous, automated, risk-based monitoring against a calibrated set of typologies including, without limitation, structuring, layering, rapid deposit-and-withdrawal patterns, exposure to mixers or other obfuscation services, interaction with sanctioned addresses, and behaviour inconsistent with the Client's stated profile. Alerts are reviewed by trained analysts under documented escalation procedures.

5. Account Reactivation Following Prolonged Inactivity

Where an account has been dormant — that is, has had no recorded user-initiated balance-changing activity — for a continuous period of twelve (12) calendar months or more, IronXLedger applies enhanced reactivation controls before processing any outbound transfer. Such controls may include refreshed identity verification, renewed sanctions screening, source-of-funds confirmation, and a minimum reactivation deposit determined by the Platform from time to time. These measures exist for the protection of the Client and the integrity of the Platform; they are not a fee, a forfeiture, or a condition precedent to ownership of the underlying balance.

6. Sanctions Compliance

IronXLedger maintains a strict prohibition on the provision of services to Restricted Persons and to persons resident, ordinarily domiciled, or located in Prohibited Jurisdictions. Sanctions screening is applied at onboarding, on each material change to Client information, and continuously against current consolidated sanctions lists. Matches are escalated to the compliance function and may result in immediate freezing of relevant assets pending investigation and, where required, statutory reporting.

7. Reporting Obligations

Suspicious activity is reported to the relevant Financial Intelligence Unit in accordance with applicable law. By accepting our Terms of Service, you acknowledge and agree that IronXLedger is, in such circumstances, prohibited from "tipping off" the subject of any such report and that the absence of a substantive response from the Platform should not be construed as inaction.

8. Recordkeeping

Records of identification, transactional activity, and internal investigations are retained for a minimum of five (5) years from the date of the last transaction or the closure of the account, and for such longer period as may be required by applicable law.

9. Governance and Training

The Program is overseen by the IronXLedger Money Laundering Reporting Officer, appointed at the level of senior management, and is reviewed at least annually. All relevant personnel undergo induction and recurrent training proportionate to their role.

10. Cooperation with Authorities

IronXLedger cooperates fully with competent regulatory, supervisory, tax, and law-enforcement authorities, and will respond to lawful requests for information in accordance with applicable law and our Privacy Policy.

11. Contact

Enquiries concerning this Policy should be addressed to support@ironxledger.com with the subject line marked COMPLIANCE — AML.