Anti-Money Laundering & KYC Policy

1. Purpose & Scope

Flux International ("Flux", "we", "us") is committed to the highest standards of anti-money laundering (AML), counter-terrorism financing (CTF) and counter-proliferation financing (CPF) compliance. This policy applies to every officer, employee, contractor and intermediary acting on behalf of Flux, and to every business client onboarded to our platform. It is reviewed at least annually and updated in line with applicable law and partner-bank requirements.

2. Regulatory Framework

Flux operates as a financial-technology platform whose regulated banking, custody and payment functions are delivered through licensed partners (the "Partner Institutions"). Flux and its Partner Institutions adhere to:

• The Financial Action Task Force (FATF) 40 Recommendations
• The Prevention of Money Laundering Act, 2002 (India) and PMLA Rules
• The U.S. Bank Secrecy Act (BSA) and USA PATRIOT Act
• The EU Anti-Money Laundering Directives (4AMLD/5AMLD/6AMLD)
• The UK Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
• UN, OFAC, HMT, EU and local sanctions regimes

3. Customer Due Diligence (CDD / KYC / KYB)

Before any account or wallet is activated, Flux performs risk-based identification and verification on every business client (KYB) and every natural person who is a director, authorised signatory or beneficial owner of 25% or more (KYC). Verification includes:

• Government-issued photo identification and proof of address
• Certificate of incorporation, register of members and constitutional documents
• Beneficial-ownership tracing through any holding entities
• Sanctions, PEP and adverse-media screening at onboarding and on an ongoing basis
• Source-of-funds and source-of-wealth assessment where required

4. Enhanced Due Diligence (EDD)

Higher-risk relationships — including those involving politically exposed persons, complex ownership structures, high-risk jurisdictions or unusual transaction patterns — are subject to Enhanced Due Diligence. EDD requires senior-management approval, additional documentary evidence, and intensified ongoing monitoring.

5. Sanctions & Prohibited Jurisdictions

Flux does not onboard clients, process transactions for, or transmit funds to/from individuals or entities subject to UN, OFAC, HMT, EU or other applicable sanctions. Services are not available to residents of, or businesses operating in, comprehensively sanctioned jurisdictions including (without limitation) North Korea, Iran, Syria, Cuba and the Russian-occupied regions of Ukraine. Every transaction is screened in real time against current sanctions lists.

6. Transaction Monitoring

All client activity is subject to ongoing automated and manual monitoring designed to detect structuring, layering, unusual velocity, geographic risk, third-party flows and other typologies of financial crime. Alerts are triaged by Flux's compliance team and, where warranted, escalated to the relevant Partner Institution and competent authority.

7. Record Keeping

Flux retains all KYC, KYB, transaction, screening and investigation records for at least five (5) years after the end of the customer relationship or the date of the transaction, whichever is later — and longer where a Partner Institution or applicable law requires.

8. Suspicious Activity Reporting

Where Flux identifies activity it knows, suspects or has reasonable grounds to suspect is connected to money laundering, terrorist financing or any other predicate offence, it will file a Suspicious Transaction Report (STR / SAR) with the appropriate Financial Intelligence Unit through its Partner Institutions. Customers are not tipped off about such filings, as required by law.

9. Governance & the MLRO

Flux has appointed a Money Laundering Reporting Officer (MLRO) responsible for the day-to-day operation of this policy, the AML programme, staff training, independent testing and reporting to senior management and the board. The MLRO can be reached at compliance@fluxinternational.org.

10. Training

All Flux personnel receive AML/CTF training at induction and at least annually thereafter, with role-specific modules for client-facing, operations and engineering staff.

11. Cooperation with Authorities

Flux cooperates fully and promptly with lawful requests from regulators, law-enforcement and tax authorities, and supports its Partner Institutions in discharging their reporting and production obligations.

12. Contact

To report a concern or request information about this policy, please write to compliance@fluxinternational.org.