Anti-Money Laundering Policy

This Anti-Money Laundering (AML) Policy establishes the framework and procedures that Vynex follows to detect, prevent, and report money laundering, terrorist financing, and other financial crimes.

This policy applies to:

• All users of the Vynex platform (individual and corporate).
• All Vynex employees, officers, contractors, and agents.
• All services offered through the Platform, including trading, staking, and wallet services.

All users must complete our tiered KYC verification process before accessing full platform features:

Vynex employs advanced monitoring systems to detect suspicious activities, including:

Flagged transactions are reviewed by our compliance team. Accounts may be temporarily restricted during investigation.

When suspicious activity is identified, Vynex will:

• 1 Immediately freeze the affected account(s) and associated transactions.
• 2 Conduct an internal investigation with documented findings.
• 3 File a Suspicious Activity Report (SAR) with the relevant Financial Intelligence Unit (FIU) if warranted.
• 4 Cooperate fully with law enforcement investigations.

Vynex screens all users against international sanctions lists including but not limited to:

• OFAC — U.S. Office of Foreign Assets Control (SDN List)
• EU Consolidated List — European Union sanctions
• UN Security Council — United Nations consolidated list
• FATF — Financial Action Task Force high-risk jurisdictions

Screening is performed at onboarding and periodically for existing users. Matches result in immediate account restriction pending review.

All Vynex team members receive comprehensive AML training covering:

• Recognition of suspicious activity indicators and red flags.
• KYC procedures and customer due diligence best practices.
• Regulatory obligations in applicable jurisdictions.
• Internal escalation and reporting procedures.

Training is conducted annually and updated whenever regulations change.

Vynex maintains comprehensive records in accordance with regulatory requirements:

• KYC documentation and identity verification records — retained for a minimum of 5 years after account closure.
• Transaction records — retained for a minimum of 5 years from the date of the transaction.
• SAR filings and internal investigation reports — retained for a minimum of 5 years from the filing date.

Vynex cooperates fully with law enforcement and regulatory bodies in their efforts to combat financial crimes. This includes:

• Responding promptly to lawful information requests and subpoenas.
• Sharing relevant transaction data and user information when legally required.
• Participating in industry information-sharing initiatives.