July, 2026

Anti-Money Laundering and Know Your Customer (AML/KYC) Policy

  1. Introduction and Commitment

1.1 Chainsett is committed to the highest standards of integrity and to the prevention of money laundering, terrorist financing, proliferation financing, and other financial crime. This policy sets out the framework of controls, procedures, and responsibilities Chainsett applies to meet that commitment.

1.2 Money laundering, terrorist financing, and sanctions evasion cause serious harm, and Chainsett does not tolerate any use of its services for these purposes. Chainsett is committed to acting in accordance with applicable anti-financial-crime law and to cooperating fully with competent authorities.

1.3 This policy applies to all directors, officers, employees, contractors, and agents of Chainsett, and governs the onboarding and ongoing management of all business clients.

2. Chainsett's Role and the Division of Responsibility

2.1 Chainsett operates as a non-custodial orchestration and compliance layer. Chainsett configures, connects, and administers payment, compliance, and accounting infrastructure on behalf of its business clients. Chainsett does not take custody of, hold, or control client funds at any stage.

2.2 Settlement of payments, and the regulated execution of transactions, is performed by licensed, regulated third-party providers ("Providers"). Certain regulated compliance functions, including on-chain transaction monitoring, sanctions screening at the transaction level, and Travel Rule information handling, are performed by or through these Providers, each of which is subject to its own regulatory obligations.

2.3 This division of responsibility means that:

(a) Chainsett conducts due diligence on its own business clients, assesses and manages client risk, and maintains the controls set out in this policy; and

(b) the regulated execution of settlement and transaction-level monitoring is carried out by licensed Providers under their own authorisations and compliance programmes.

2.4 Chainsett selects Providers with regard to their regulatory standing and the adequacy of their own AML/CFT controls, and works only with Providers that maintain appropriate authorisations and controls for the services they perform.

  1. Regulatory Framework

3.1 Chainsett conducts its activities in alignment with the European Union's anti-money laundering and counter-terrorist-financing framework and applicable Latvian law, including as relevant:

(a) the EU Anti-Money Laundering Directives and the EU Anti-Money Laundering Regulation (AMLR), as applicable and as they come into effect;

(b) the Markets in Crypto-Assets Regulation (MiCA);

(c) the recast Transfer of Funds Regulation governing information accompanying transfers (the "Travel Rule"), as applied by the relevant regulated parties;

(d) applicable European Union and United Nations sanctions regimes; and

(e) applicable Latvian legislation implementing and supplementing the above.

3.2 Where any activity within the scope of Chainsett's service constitutes a regulated crypto-asset service or a regulated payment service, that activity is performed by an appropriately licensed Provider, and the corresponding regulatory obligations are met by that Provider. Chainsett does not hold itself out as a licensed crypto-asset service provider or payment institution.

3.3 Chainsett keeps this policy under review to reflect changes in law and regulation, including the phased application of the AMLR and the technical standards issued by the Anti-Money Laundering Authority (AMLA).

  1. Risk-Based Approach

4.1 Chainsett applies a risk-based approach. The nature and extent of due diligence and ongoing monitoring applied to a client is proportionate to the money-laundering and terrorist-financing risk that client presents.

4.2 Chainsett maintains a documented business-wide risk assessment that considers the risks arising from its clients, the jurisdictions in which it and its clients operate, the products and services provided, the delivery channels used, and the Providers relied upon. This assessment is reviewed periodically and updated where the risk profile changes.

4.3 Each client is assessed at onboarding and assigned a risk rating (for example, standard, elevated, or high). The risk rating determines the intensity of due diligence applied and the frequency of subsequent review.

4.4 Risk factors considered include, without limitation:

(a) Client risk — the client's ownership and control structure, the transparency of its beneficial ownership, its business activity and reputation, and whether it or its beneficial owners are politically exposed persons;

(b) Geographic risk — the client's country of establishment and operation, the jurisdictions of its counterparties, and whether any of these are subject to sanctions, are identified as high-risk third countries, or present heightened corruption or financial-crime risk;

(c) Product and service risk — the nature of the services the client will use and their susceptibility to misuse;

(d) Channel risk — the manner in which the client is onboarded and interacts with the service; and

(e) Transaction risk — the expected value, volume, frequency, and counterparties of the client's activity.

5. Customer Due Diligence (KYC / KYB)

5.1 Chainsett does not establish a business relationship with a client until the applicable due diligence has been completed satisfactorily.

5.2 For each business client, Chainsett performs Know Your Business and Know Your Customer checks, which include:

(a) identifying the client and verifying its identity, including its legal name, registration number, legal form, and registered address, on the basis of reliable and independent documents, data, or information;

(b) verifying that the business is validly registered and in good standing;

(c) identifying the beneficial owners of the client and taking reasonable measures to verify their identity, so that Chainsett is satisfied it knows who ultimately owns or controls the client;

(d) understanding the ownership and control structure of the client where it is a legal person, trust, or similar arrangement;

(e) identifying and verifying the identity of directors and of the individuals authorised to act on behalf of the client;

(f) obtaining information on the intended nature and purpose of the business relationship and the client's anticipated activity; and

(g) screening the client, its beneficial owners, and its authorised representatives against applicable sanctions lists, politically-exposed-person databases, and adverse-media sources.

5.3 Identity verification is conducted through established, specialist identity-verification providers, using measures that may include document verification, liveness detection, and biometric matching as appropriate to the assessed risk.

5.4 Where Chainsett is unable to complete customer due diligence to its satisfaction, it will not enter into or will terminate the business relationship, will not carry out the requested service, and will consider whether the circumstances give rise to an obligation to make a report to the relevant authority.

6. Enhanced Due Diligence

6.1 Enhanced due diligence (EDD) is applied where a client, transaction, or relationship presents a higher risk, including where:

(a) the client or a beneficial owner is a politically exposed person, a family member of a PEP, or a known close associate of a PEP;

(b) the client is established in, or has significant connections to, a high-risk third country or a jurisdiction subject to enhanced monitoring;

(c) the client has a complex or opaque ownership structure that appears to lack a clear commercial rationale;

(d) the client's activity is inconsistent with its stated business or expected profile; or

(e) the relationship otherwise presents characteristics associated with higher financial-crime risk.

6.2 Enhanced due diligence measures may include obtaining additional identification and verification information, establishing the source of funds and source of wealth, obtaining senior-management approval to establish or continue the relationship, and applying increased ongoing monitoring.

6.3 Relationships involving politically exposed persons are subject to senior-management approval, establishment of source of wealth and source of funds, and enhanced ongoing monitoring for the duration of the relationship.

7. Sanctions

7.1 Chainsett does not knowingly establish a relationship with, or facilitate any activity involving, any person, entity, or jurisdiction subject to applicable sanctions, including those maintained by the European Union, the United Nations, and other applicable regimes.

7.2 Clients, their beneficial owners, and their authorised representatives are screened against applicable sanctions lists at onboarding and on an ongoing basis, including when relevant lists are updated. Transaction-level sanctions screening is performed by or through licensed Providers as part of the settlement process.

7.3 Where a sanctions match is identified or suspected, Chainsett will suspend the relevant activity, take steps to confirm or discount the match, and comply with any applicable obligation to freeze assets, refrain from dealing, or report to the relevant authority. Chainsett will not proceed with any activity that would breach applicable sanctions.

8. Ongoing Monitoring

8.1 Chainsett maintains ongoing monitoring of its business relationships proportionate to the assessed risk, in order to ensure that the activity conducted remains consistent with its knowledge of the client, the client's business, and the client's risk profile.

8.2 Ongoing monitoring includes keeping client due diligence information current and reviewing it at intervals appropriate to the client's risk rating, and reviewing activity for consistency with the expected profile.

8.3 Transaction monitoring and screening for financial-crime risk is performed through specialist compliance infrastructure operated by licensed Providers, using capabilities that may include wallet and address screening, real-time and ongoing transaction monitoring (Know Your Transaction), behavioural analysis, risk scoring, and screening for exposure to high-risk sources such as sanctioned addresses, mixing services, and high-risk jurisdictions.

8.4 Alerts arising from monitoring are subject to review, investigation, and, where appropriate, escalation in accordance with this policy.

9. Travel Rule

9.1 Transfers of crypto-assets executed through Chainsett's Providers are subject to the information requirements of the recast Transfer of Funds Regulation (the "Travel Rule"), under which originator and beneficiary information is collected and, where required, transmitted alongside the transfer.

9.2 As Chainsett does not itself execute crypto-asset transfers, the collection and transmission of Travel Rule information in respect of executed transfers is performed by the licensed Provider executing the transfer. Chainsett supports compliance by collecting and maintaining the relevant client information required to enable this.

  1. Reporting of Suspicious Activity

10.1 Where Chainsett, or any of its personnel, knows, suspects, or has reasonable grounds to suspect that activity may involve money laundering, terrorist financing, proceeds of crime, or other reportable conduct, that person must escalate the matter internally in accordance with this policy without delay.

10.2 Chainsett assesses escalated matters and, where required by law, makes a report to the relevant Financial Intelligence Unit or other competent authority.

10.3 Chainsett and its personnel must not disclose to a client, or to any third party, that a report has been or may be made, or that an investigation is being or may be carried out, where such disclosure would or might prejudice an investigation ("tipping off"). Any question about whether a disclosure is permitted must be referred internally before any communication is made.

10.4 No employee will suffer detriment for making, in good faith, an internal escalation or report of suspected financial crime.

  1. Record Keeping

11.1 Chainsett retains records of customer due diligence, the supporting documents and information obtained, the business relationship, and any transactions and reports, for the minimum period required by applicable law, which is not less than five years from the end of the business relationship or the date of the relevant transaction, unless a longer period is required.

11.2 Records are maintained securely, in a manner that allows them to be retrieved without undue delay, and are made available to competent authorities on lawful request.

11.3 Records are retained and processed in accordance with applicable data-protection law, including the General Data Protection Regulation, and Chainsett's Privacy Policy.

  1. Governance, Roles, and Responsibilities

12.1 Overall responsibility for AML/CFT compliance rests with Chainsett's management, which is responsible for establishing, maintaining, and overseeing the adequacy of this policy and the controls it describes.

12.2 Chainsett designates a person responsible for AML/CFT compliance ("the Compliance Officer" or equivalent), whose responsibilities include maintaining this policy and the business-wide risk assessment, overseeing due diligence and monitoring, receiving and assessing internal escalations, making external reports where required, acting as the point of contact for competent authorities, and reporting to management on the operation of the AML/CFT programme. [Insert name/role and contact where appropriate.]

12.3 Management ensures that adequate resources are allocated to the AML/CFT function and that it operates with appropriate independence and authority.

  1. Training and Awareness

13.1 Chainsett ensures that relevant personnel are made aware of their obligations under this policy and under applicable law, and understand the risks of money laundering and terrorist financing relevant to Chainsett's business.

13.2 Training is provided at onboarding and periodically thereafter, and is updated to reflect changes in law, regulation, and financial-crime typologies.

  1. Client Obligations and Cooperation

14.1 Clients are required to provide accurate and complete information in response to due diligence and ongoing monitoring requests, and to update Chainsett promptly of any material change to the information previously provided, including changes to ownership, control, or the nature of their business.

14.2 Chainsett may request further information or documentation at any time during the relationship. Failure to provide requested information within a reasonable period, or the provision of information that is false or misleading, may result in suspension or termination of the relationship and, where required, a report to the relevant authority.

14.3 Clients must not use, or attempt to use, Chainsett's services or the services of its Providers for any unlawful purpose, including money laundering, terrorist financing, sanctions evasion, fraud, or any other financial crime.

  1. Review of this Policy

15.1 Chainsett reviews this policy periodically, and in any event in response to material changes in applicable law, regulation, supervisory expectations, or Chainsett's own risk profile and business model.

15.2 Chainsett may amend this policy from time to time. The current version is the version published on Chainsett's website.

9. Contact

Questions regarding this policy, or matters relating to AML/CFT compliance, may be directed to info@chainsett.com

This document describes Chainsett's internal policy framework and does not constitute legal advice or a representation of regulated status. It should be read together with Chainsett's Terms of Service, Privacy Policy, and other published policies.