AML / ATF Compliance.

AML/ATF Compliance.

Anti-money-laundering and counter-terrorism-financing program, KYC tiers, monitoring and reporting obligations.

ETHERANOX INC. Last updated: 04.06.2026

1. Introduction

This Anti-Money Laundering and Anti-Terrorist Financing Compliance Statement (the “Statement”) explains the principles and controls adopted by ETHERANOX INC. (“Etheranox”, “we”, “our”, or “us”) to prevent, detect, investigate, and report money laundering, terrorist activity financing, sanctions evasion, fraud, and other financial crime risks in connection with our services.

Etheranox provides virtual currency-related money services primarily to individual customers, retail users, and natural persons.

These services may include, where supported by Etheranox from time to time:

customer onboarding and user profile registration;
virtual currency exchange services;
fiat-to-virtual-currency and virtual-currency-to-fiat conversion;
virtual currency transfers, receipts, or remittances;
fiat on-ramp and off-ramp services;
transaction monitoring and blockchain wallet screening;
payment, external wallet address screening, transaction monitoring.

As part of its services, Etheranox may verify customer identity, assess customer and transaction risk, monitor fiat and virtual currency activity, screen wallet addresses, apply sanctions and fraud-prevention controls, collect Travel Rule information where required, maintain compliance records, and file reports with FINTRAC or other competent authorities where required by law.

This Statement applies to all persons accessing or using Etheranox’s services, including individual customers, users, website visitors, senders, receivers, payors, payees, wallet owners, transaction counterparties, and, where applicable, business users, legal entities, authorised representatives, directors, officers, beneficial owners, controllers, agents, and other relevant persons.

This Statement is a public summary of Etheranox’s AML/ATF, sanctions, and financial crime prevention approach. Etheranox maintains internal policies, procedures, risk assessments, and controls that may be more detailed and are not publicly disclosed for security, legal, regulatory, and operational reasons.

2. Regulatory Framework

Etheranox is committed to complying with applicable anti-money laundering, anti-terrorist financing, sanctions, fraud prevention, and financial crime requirements, including, where applicable:

the Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("PCMLTFA");
regulations issued under the PCMLTFA;
FINTRAC requirements and guidance applicable to MSBs and dealers in virtual currency;
customer identification and verification requirements;
recordkeeping requirements applicable to virtual currency and fiat transactions;
Suspicious Transaction Report ("STR") obligations;
Large Virtual Currency Transaction Report ("LVCTR") obligations;
Large Cash Transaction Report ("LCTR") obligations, where applicable;
Travel Rule requirements for electronic funds transfers and virtual currency transfers, where applicable;
Canadian sanctions laws and regulations;
terrorist property and listed person or entity reporting obligations;
sanctions evasion reporting obligations;
applicable requirements of banking partners, payment processors, liquidity providers, blockchain infrastructure providers, wallet screening providers, compliance technology vendors, and other financial or operational partners;
applicable international standards, including risk-based principles issued by the Financial Action Task Force ("FATF").

Etheranox maintains a risk-based compliance program designed to identify, assess, manage, and mitigate money laundering, terrorist activity financing, sanctions evasion, fraud, cybersecurity-related financial crime, and other illicit finance risks associated with its customers, transactions, products, services, delivery channels, jurisdictions, external wallet addresses, third parties, and technologies.

3. Our Compliance Commitment

Etheranox does not tolerate the use of its services for money laundering, terrorist financing, terrorist activity financing, sanctions evasion, fraud, illegal activity, or any activity designed to conceal the origin, ownership, destination, purpose, or control of funds or virtual currency.

Etheranox is committed to:

conducting appropriate due diligence on individual customers, users, transaction counterparties, external wallet address owners or controllers, and other relevant persons;
verifying the identity of customers where required by law or internal policy;
understanding the purpose and intended nature of customer relationships and transaction activity;
assessing the risk profile of customers, user profiles, external wallet addresses, transactions, products, services, delivery channels, jurisdictions, and counterparties;
applying enhanced due diligence where higher risk is identified;
monitoring fiat and virtual currency transactions on a risk-sensitive basis;
screening customers, counterparties, wallet addresses, and transaction flows against applicable sanctions, terrorist, restricted-party, politically exposed person, adverse media, blockchain risk, and high-risk databases;
identifying, escalating, and reporting suspicious, unusual, prohibited, or high-risk activity where required;
maintaining appropriate records;
training relevant personnel;
periodically reviewing and improving AML/ATF, sanctions, and financial crime controls.

4. Customer Due Diligence

Etheranox applies customer due diligence (“CDD”) measures before and during the provision of services. These measures are designed to identify and verify customers, understand expected activity, assess risk, and prevent misuse of Etheranox’s services.

Depending on the nature and risk profile of the customer, user profile, transaction, product, external wallet address, or relationship, Etheranox may collect and verify information relating to individuals, including:

full legal name;
date of birth;
contact details;
nationality, citizenship, or country of residence, where required or risk-relevant;
government-issued identification documents;
selfie, liveness, biometric, or facial verification information, where applicable;
occupation or nature of principal business;
transaction purpose and expected transaction behaviour;
expected use of the services and anticipated transaction profile;
geolocation, IP address, device, browser, and session indicators;
other information reasonably required for compliance, fraud prevention, sanctions screening, transaction monitoring, Travel Rule, recordkeeping, or risk assessment purposes.

Etheranox may verify customer information using documents, independent data sources, identity verification providers, screening tools, fraud prevention systems, blockchain analytics tools, payment information, transaction data, device information, IP address information, public databases, or other information reasonably available to Etheranox.

Etheranox may refuse onboarding, restrict services, suspend activity, delay or decline transactions, request additional information, or terminate a relationship where required information is not provided, where information is false, misleading, incomplete, or inconsistent, or where the customer, external wallet address, transaction, jurisdiction, counterparty, product, service, or activity presents unacceptable AML/ATF, sanctions, fraud, legal, reputational, security, operational, or regulatory risk.

5. Risk-Based Approach

Etheranox applies a risk-based approach to AML/ATF, sanctions, fraud prevention, and financial crime compliance. This means that the level of due diligence, monitoring, and controls applied to a customer, user profile, external wallet address, transaction, counterparty, product, service, jurisdiction, or relationship may vary depending on the risk identified.

Risk factors may include:

identity, residence, nationality, citizenship, and geographic exposure of the customer;
customer occupation, business activity, or source of funds;
customer transaction behaviour and expected transaction activity;
transaction volume, value, frequency, velocity, asset type, and corridors;
fiat payment method country, bank account country, card issuing country, billing country, IP address, device location, and customer location indicators, where relevant;
wallet address exposure, external wallet address ownership or control, blockchain behaviour, and wallet address risk score;
exposure to mixers, tumblers, darknet markets, ransomware, scams, stolen funds, sanctioned addresses, sanctioned entities, or other high-risk blockchain typologies;
source of funds or source of wealth indicators;
use of customer-provided external wallet addresses, including self-hosted wallet addresses, newly created wallet addresses, high-risk exchanges, or counterparties;
refund, reversal, dispute, chargeback, or payment failure activity, where relevant;
geographic exposure to high-risk or sanctioned jurisdictions;
adverse media, sanctions, politically exposed person, head of international organization, law enforcement, or restricted-party exposure;
unusual, inconsistent, or suspicious transaction behaviour;
products, services, or delivery channels that increase anonymity, speed, complexity, or cross-border exposure;
ownership structure, control structure, business model, website, customer base, settlement arrangement, and operating jurisdictions, where applicable to business users or legal entities.

Where higher risk is identified, Etheranox may apply enhanced due diligence, additional monitoring, transaction restrictions, user profile restrictions, transaction limits, external wallet address restrictions, source of funds checks, source of wealth checks, senior management approval, or other measures appropriate to the risk.

6. Enhanced Due Diligence

Etheranox may conduct enhanced due diligence (“EDD”) where a customer, user profile, external wallet address, transaction, payment method, counterparty, jurisdiction, product, service, or relationship presents higher risk.

Enhanced due diligence may include:

verifying identity, residence, location, user profile activity, external wallet address ownership or control, transaction purpose, or payment method ownership;
requesting additional identity, user profile, external wallet address, ownership, control, or financial information;
reviewing source of funds and source of wealth;
reviewing high-risk transactions, external wallet address activity or blockchain exposure, customer segments, jurisdictions, or counterparties;
obtaining additional documents such as bank statements, corporate records, invoices, contracts, tax filings, proof of income, proof of sale, or other supporting evidence;
verifying bank account, payment method, or external wallet address ownership or control, where applicable;
applying closer ongoing monitoring;
requiring senior management or compliance approval;
restricting certain products, countries, transaction types, assets, external wallet addresses, counterparties, payment methods, or transaction flows.

Etheranox may decline, restrict, suspend, or terminate any relationship where the risk cannot be adequately understood, controlled, or mitigated.

7. Sanctions Screening and Restricted Parties

Etheranox screens relevant persons, entities, counterparties, wallet addresses, and transaction flows against sanctions and restricted-party lists.

Relevant persons and entities may include individual customers, users, senders, receivers, originators, beneficiaries, transaction counterparties, wallet owners, and, where applicable, business users, legal entities, directors, officers, authorised representatives, beneficial owners, controllers, and related parties.

Etheranox does not provide services to any person or entity that is sanctioned, restricted, owned or controlled by a sanctioned person or entity, acting for or on behalf of a sanctioned person or entity, located in a prohibited jurisdiction, or otherwise prohibited under applicable law.

Etheranox may block, reject, delay, freeze, suspend, restrict, or report activity involving:

sanctioned persons;
sanctioned countries, territories, regions, or jurisdictions;
virtual currency wallet addresses associated with sanctioned persons, sanctioned entities, or sanctions evasion;
transactions that may involve sanctions evasion;
transactions involving high-risk intermediaries or obfuscation techniques designed to conceal a sanctions connection;
goods, services, external wallet address exposure, payment flows, counterparties, or jurisdictions prohibited by sanctions or applicable restrictions.

Etheranox may also apply additional restrictions required by law, regulators, banking partners, payment processors, liquidity providers, blockchain analytics providers, blockchain infrastructure providers or wallet screening providers, financial partners, or internal risk policies.

8. Politically Exposed Persons, Heads of International Organizations, and High-Risk Persons

Etheranox may screen relevant persons against politically exposed person (“PEP”), head of international organization (“HIO”), family member, close associate, adverse media, law enforcement, and other high-risk databases.

Relevant persons may include individual customers, users, senders, receivers, counterparties, external wallet address owners or controllers.

Where a relevant person is identified as higher risk, Etheranox may apply enhanced due diligence, obtain additional information, require senior management approval, conduct closer monitoring, impose restrictions, or refuse or terminate the relationship.

9. Transaction Monitoring and Blockchain Analytics

Etheranox monitors fiat payments, virtual currency exchange transactions, user profile activity, external wallet addresses, blockchain exposure, and related behaviour to identify unusual, inconsistent, suspicious, prohibited, or high-risk activity.

Monitoring may include review of:

transaction size, value, frequency, and velocity;
high-value or high-frequency activity;
rapid or unusual movement of funds or virtual currency connected to an exchange transaction;
activity inconsistent with the customer's expected transaction activity, declared purpose, source of funds, or transaction profile;
bank transfers, card payments, payment failures, chargebacks, refunds, or reversals, where applicable;
exchange transactions, fiat payments, virtual currency delivery transactions, transaction references, or blockchain transaction hashes;
wallet addresses, transaction hashes, blockchain exposure, and counterparty wallet address exposure;
exposure to sanctioned addresses, sanctioned entities, darknet markets, ransomware, scams, stolen funds, fraud clusters, mixers, tumblers, peel chains, chain-hopping, bridges, or other high-risk typologies;
newly created wallets followed by immediate high-value transfers;
frequent changes in customer-provided external wallet addresses;
repeated transactions below reporting thresholds;
customer location, IP address, device, browser, session, or geolocation indicators;
high-risk jurisdictions or transaction corridors;
suspicious customer, user profile, external wallet address, counterparty, or business-user behaviour;
attempts to bypass geographic, sanctions, fraud, transaction monitoring, wallet, payment, account, or compliance restrictions.

Etheranox may use blockchain analytics tools, fraud-prevention systems, sanctions screening providers, identity verification providers, monitoring rules, manual review, case management workflows, and other controls to detect and investigate suspicious or high-risk activity.

Etheranox may request additional information, delay or decline transactions, restrict user profile access, suspend processing, reject external wallet addresses, delay virtual currency delivery, or terminate services where transaction or wallet activity cannot be reasonably explained or presents unacceptable risk.

10. Travel Rule and External Wallet Address Controls

Where applicable, Etheranox complies with Travel Rule requirements for electronic funds transfers and virtual currency transfers.

Etheranox may collect, transmit, verify, or retain originator and beneficiary information, including information relating to senders, receivers, wallet addresses, account identifiers, transaction references, and counterparties, where required by law or internal policy.

Etheranox may apply controls to customer-provided external wallet addresses, including self-hosted wallet addresses, and blockchain counterparties. These controls may include:

wallet address screening;
wallet ownership or control checks;
proof-of-control measures, where appropriate;
external wallet address verification;
monitoring of wallet risk exposure;
restrictions on high-risk or unsupported external wallet addresses;
limits, holds, or rejection for higher-risk exchange transactions or virtual currency delivery;
rejection or escalation of transfers involving prohibited or high-risk wallet exposure;
review of missing, incomplete, or inconsistent originator or beneficiary information.

Etheranox may refuse, suspend, delay, or reject an exchange transaction or virtual currency delivery where required information is missing, where wallet ownership cannot be reasonably established, where the wallet presents unacceptable risk, or where processing the transfer would violate applicable law, sanctions requirements, Travel Rule requirements, partner requirements, or internal risk policies.

11. Suspicious Activity and Reporting

Etheranox reviews unusual or suspicious activity and escalates matters internally where appropriate.

Where required by applicable law, Etheranox will report suspicious transactions, attempted suspicious transactions, suspected terrorist property, suspected listed person or entity property, suspected sanctions evasion, or other reportable activity to FINTRAC or other competent authorities.

Etheranox may be legally restricted from informing a customer, user, counterparty, business user, representative, beneficial owner, controller, or other person that a report has been made or that an investigation, review, escalation, or reporting decision is ongoing.

Etheranox may also cooperate with lawful requests from regulators, law enforcement, courts, government authorities, banking partners, payment processors, or other competent parties where required or permitted by law.

12. Large Virtual Currency Transactions and Other Regulatory Reporting

Etheranox maintains processes designed to identify and report transactions that meet applicable reporting thresholds and criteria.

Where required, Etheranox may file reports relating to:

suspicious transactions or attempted suspicious transactions;
large virtual currency transactions;
large cash transactions, where applicable;
electronic funds transfers, where applicable;
listed person or entity property;
terrorist property;
sanctions evasion;
other reportable activity required by law or competent authorities.

Etheranox may aggregate transactions under applicable rules, including relevant 24-hour rules, where required. Etheranox may also retain supporting records, exchange rate methodology information, transaction data, customer data, external wallet address information, blockchain analytics outputs, and case notes necessary to support regulatory reporting and compliance decisions.

13. Prohibited Use of Services

Etheranox’s services must not be used for:

money laundering;
terrorist financing or terrorist activity financing;
sanctions evasion;
fraud;
identity theft;
illegal goods or services;
bribery or corruption;
tax evasion;
human trafficking or exploitation;
child sexual exploitation material;
ransomware, cybercrime, scam activity, phishing, hacking, or other technology-enabled financial crime;
unlicensed or illegal gambling;
sale of counterfeit, stolen, restricted, or prohibited goods;
transactions involving sanctioned persons, entities, countries, territories, regions, or wallet addresses;
transactions involving funds, virtual currency, external wallet addresses, or counterparties connected to prohibited activity;
transactions designed to conceal the origin, ownership, destination, purpose, or control of funds or virtual currency;
use of mixers, tumblers, obfuscation tools, chain-hopping, privacy-enhancing techniques, or other mechanisms for illicit concealment or evasion;
use of false, misleading, incomplete, or inconsistent information;
activity designed to bypass Etheranox's compliance, sanctions, fraud, blockchain analytics, transaction monitoring, geographic, external wallet address, payment, user profile, or transaction controls;
activity designed to bypass Etheranox's compliance, sanctions, fraud, blockchain analytics, transaction monitoring, geographic, external wallet address, payment, user profile, or transaction controls;

Etheranox may reject, restrict, suspend, or terminate any user profile, customer relationship, transaction, external wallet address, payment method, payment flow, business relationship, or other relationship that presents unacceptable legal, compliance, financial crime, sanctions, fraud, reputational, security, operational, or regulatory risk.

14. Customer and User Responsibilities

Customers and users must provide accurate, complete, and up-to-date information when requested by Etheranox.

Customers and users must use Etheranox’s services only for lawful purposes and must not engage in money laundering, terrorist financing, terrorist activity financing, sanctions evasion, fraud, illegal activity, or other prohibited activity.

Customers and users must ensure that information relating to their identity, residence, location, payment method, wallet address, transaction purpose, source of funds, source of wealth, expected use of the services, and transaction activity is accurate, complete, and not misleading.

Customers and users must cooperate with Etheranox’s compliance, security, due diligence, enhanced due diligence, transaction monitoring, sanctions screening, blockchain analytics, Travel Rule, fraud prevention, external wallet address verification, and information requests.

Failure to comply with these responsibilities may result in transaction rejection, transaction delays, external wallet address restrictions, user profile restrictions, service suspension, termination, reporting to competent authorities, and refusal of future service.

15. Geographic and Jurisdictional Controls

Etheranox may restrict or prohibit access to its services from certain countries, territories, regions, jurisdictions, transaction corridors, wallet address clusters, counterparties, or blockchain exposures based on legal, regulatory, sanctions, AML/ATF, fraud, financial crime, banking partner, payment processor, liquidity provider, blockchain analytics, or internal risk considerations.

Etheranox may use IP address, device information, residential address, nationality, citizenship, billing country, payment method country, bank account country, wallet address, blockchain exposure, transaction data, user profile activity or transaction activity, customer location, business address, settlement account country, customer base, and other indicators to assess jurisdictional risk.

Where available information indicates a potential restricted jurisdiction connection, inaccurate location information, inconsistent user profile activity or transaction activity, unusual transaction behavior, high-risk wallet exposure, sanctions concern, or other jurisdictional risk, Etheranox may request additional information, apply enhanced review, restrict certain transactions, suspend processing, delay transaction processing or virtual currency delivery, terminate services, or take other measures permitted under this Statement and applicable law.

16. Recordkeeping and Retention

Etheranox maintains records relating to customer due diligence, identity verification, entity verification where applicable, beneficial ownership where applicable, authority verification where applicable, user profile activity, fiat transactions, virtual currency transactions, wallet addresses, transaction hashes, sanctions screening, PEP/HIO screening, adverse media screening, risk assessments, transaction monitoring, blockchain analytics, Travel Rule information, regulatory reporting, compliance reviews, and service actions or user profile actions.

Records may be retained after the end of a customer, user profile, business, or other relevant relationship where required or permitted for legal, regulatory, audit, reporting, fraud prevention, dispute handling, investigation, sanctions, security, operational, or legitimate business purposes.

Etheranox retains AML/ATF and compliance records for the periods required by applicable law and internal policies. Where multiple retention periods apply, Etheranox may retain records for the longest applicable period.

17. Training and Compliance Governance

Etheranox maintains internal AML/ATF, sanctions, fraud prevention, and financial crime compliance governance appropriate to the nature, size, complexity, and risk profile of its business.

This may include:

appointment of an AML/ATF Compliance Officer;
written compliance policies and procedures;
a business-wide AML/ATF risk assessment;
customer identification and verification procedures;
sanctions screening procedures;
transaction monitoring and escalation procedures;
blockchain analytics and wallet screening controls;
Travel Rule procedures;
suspicious activity review and reporting procedures;
large virtual currency transaction reporting procedures;
listed person or entity property reporting procedures;
recordkeeping procedures;
employee training;
independent review and testing of compliance controls;
periodic review and improvement of compliance systems.

Relevant employees, officers, contractors, agents, and authorised persons receive training appropriate to their responsibilities and exposure to AML/ATF, sanctions, fraud, virtual currency, cybersecurity, and financial crime risks.

18. Use of Personal Information

Etheranox may collect, use, disclose, and retain personal information, customer information, transaction information, device information, identity information, verification information, location information, payment method information, user profile information, external wallet address information, blockchain analytics information, and, where applicable, business, representative, beneficial ownership, and control information as described in Etheranox’s Privacy Policy.

This information may be used to:

verify identity, residence, location, payment method, user profile, external wallet address, transaction, and, where applicable, business information;
perform KYC checks;
assess customer, user profile, transaction, external wallet address, payment method, jurisdictional, business, and counterparty risk;
conduct sanctions, PEP, HIO, adverse media, restricted-party, and blockchain exposure screening;
monitor transactions, external wallet address exposure, user profile activity, and platform activity;
detect and prevent fraud, sanctions evasion, money laundering, terrorist activity financing, and other financial crime;
comply with AML/ATF, sanctions, Travel Rule, recordkeeping, and reporting obligations;
respond to regulatory, law enforcement, court, partner, or legal requests;
enforce this Statement, Etheranox's Terms of Service, and Etheranox's internal risk policies.

19. Refusal, Suspension, Restriction, or Termination of Services

Etheranox may refuse, suspend, restrict, delay, or terminate access to its services where:

required information is not provided;
information provided is false, misleading, incomplete, or inconsistent;
identity, payment method, transaction, external wallet address, ownership, control, authority, or business information cannot be verified;
sanctions, AML/ATF, fraud, financial crime, legal, reputational, security, operational, or regulatory concerns are identified;
transaction, external wallet address, or user profile activity is suspicious, unusual, prohibited, or inconsistent with the customer's expected activity, declared purpose, source of funds, source of wealth, transaction profile, or business activity;
a customer, user profile, transaction, payment method, wallet address, receiving wallet address, bank account or payment method, jurisdiction, product, service, counterparty, business relationship, ownership structure, or activity falls outside Etheranox's risk appetite;
a customer, counterparty, business user, representative, beneficial owner, controller, wallet address, or related party is connected to a restricted jurisdiction or sanctioned exposure;
a customer, user, counterparty, business user, representative, beneficial owner, controller, or related party attempts to bypass Etheranox's controls;
continuing the relationship would violate law, regulation, sanctions requirements, FINTRAC requirements, banking partner requirements, payment processor requirements, liquidity provider requirements, blockchain infrastructure provider or wallet screening provider requirements, or Etheranox's internal risk policies.

Etheranox may also delay or refuse transaction processing, delay virtual currency delivery, reject transactions, reverse transactions where permitted, restrict user profile access, reject external wallet addresses, retain records, or report activity where required or permitted by law, contract, partner requirements, or applicable compliance obligations.

20. Updates to This Statement

Etheranox may update this Statement from time to time to reflect changes in law, regulation, FINTRAC guidance, sanctions requirements, FATF standards, product availability, supported assets, supported jurisdictions, virtual currency services, operational controls, partner requirements, technology, or internal risk assessment.

The most recent version of this Statement will be made available on Etheranox’s website or through another appropriate channel.

The “Last updated” date at the top of this Statement indicates when it was last revised.

Last updated · June 2026

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