Anti-Money Laundering Policy

1. Introduction and Purpose

CODEGENIX LTD. ("Vertex," "we," "our," or "us"), Company Number: 16808123, is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines our procedures and controls to ensure compliance with applicable laws and regulations.

This policy applies to all users of the Vertex platform, including buyers, specialists, and any third parties involved in transactions on our platform.

2. Legal Framework

Our AML program is designed to comply with:

• EU Anti-Money Laundering Directives (AMLD)
• UK Money Laundering Regulations 2017
• Financial Action Task Force (FATF) Recommendations
• Relevant national laws in jurisdictions where we operate

3. Know Your Customer (KYC) Procedures

We apply appropriate customer due diligence measures in accordance with applicable laws and regulations. The extent and nature of verification depends on the risk assessment of each customer relationship and transaction type.

4. Transaction Monitoring

4.1 Ongoing Monitoring

We continuously monitor transactions for suspicious activity, including:

• Unusual transaction patterns or volumes
• Transactions inconsistent with expected user behavior
• Rapid movement of funds
• Transactions with high-risk jurisdictions
• Multiple accounts or identity concerns

4.2 Automated Detection

Our systems employ automated monitoring tools to flag potentially suspicious transactions for manual review by our compliance team.

5. Risk-Based Approach

5.1 Risk Assessment

We apply a risk-based approach to customer due diligence, considering:

• Customer type and business relationship
• Geographic risk factors
• Transaction type and value
• Delivery channel and payment method

5.2 Enhanced Due Diligence

For higher-risk customers or transactions, we apply enhanced due diligence measures, including additional documentation requirements, senior management approval, and ongoing enhanced monitoring.

6. Suspicious Activity Reporting

6.1 Internal Reporting

All employees and contractors are trained to identify and report suspicious activity.

6.2 External Reporting

When required by law, we report suspicious activities to relevant authorities, including:

• National Crime Agency (NCA) in the UK
• Relevant Financial Intelligence Units (FIUs) in other jurisdictions

7. Sanctions Compliance

We screen all users and transactions against:

• UN Consolidated Sanctions List
• EU Consolidated List
• UK Sanctions List
• US OFAC Sanctions Lists
• Other relevant national and international sanctions lists

Users from sanctioned countries or matching sanctioned individuals/entities are prohibited from using our platform.

8. Record Keeping

We maintain comprehensive records in accordance with legal requirements:

• Customer identification documents: 5 years after relationship ends
• Transaction records: 5 years from transaction date
• Suspicious activity reports: 5 years from report date
• Training records: 5 years from training date

9. Staff Training

All relevant staff receive AML training that covers:

• Legal obligations and consequences of non-compliance
• Recognition of suspicious activity
• Internal reporting procedures
• Customer due diligence requirements

Training is provided upon hiring and refreshed annually, with additional training for role changes or regulatory updates.

10. User Obligations

By using Vertex, you agree to:

• Provide accurate and truthful information during registration and verification
• Promptly update any changes to your personal information
• Not use the platform for money laundering or any illegal purpose
• Cooperate with any verification or investigation requests
• Not circumvent or attempt to circumvent our AML controls

Failure to comply may result in account suspension, termination, and reporting to relevant authorities.

11. Account Restrictions

We reserve the right to:

• Request additional verification at any time
• Delay, block, or refuse transactions that appear suspicious
• Suspend or terminate accounts that fail verification or pose compliance risks
• Report suspicious activity to authorities without prior notice to the user

12. Policy Updates

This AML Policy is reviewed and updated at least annually or when there are significant regulatory changes. Users will be notified of material changes via email or platform notification.