Anti-Money Laundering & Counter-Terrorist Financing Policy

Apexx Capital is the trading name of Veltrix Global Ltd., an international business company incorporated under the laws of the Republic of the Marshall Islands.

• Company Name: Veltrix Global Ltd.
• Trading Name: Apexx Capital
• Registration Number: 139285
• Registered Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands MH96960
• Registered Agent: The Trust Company of the Marshall Islands, Inc.
• Website: apexx-capital.com
• Support Email: support@apexx-capital.com

For the purposes of this Policy, the terms "Company," "Apexx Capital," "we," "us," or "our" refer to Veltrix Global Ltd., operating under the trading name Apexx Capital.

The terms "Client," "you," "your," or "user" refer to any person or legal entity that accesses the website, opens an account, submits documents, makes payments, uses the platform, or otherwise uses the services.

The purpose of this Policy is to establish procedures designed to reduce the risk that Apexx Capital's website, platform, account services, payment channels, and business operations are used for:

• Money laundering
• Terrorist financing
• Sanctions evasion
• Fraud
• Identity theft
• Payment abuse
• Chargeback abuse
• Market abuse
• Use of stolen funds
• Use of stolen payment methods
• Use of nominee or third-party accounts
• Other unlawful or suspicious activity

Apexx Capital is committed to applying a risk-based approach to client onboarding, verification, monitoring, payment review, and account activity.

This Policy applies to:

• All clients
• Prospective clients
• Corporate clients
• Authorised representatives
• Beneficial owners
• Directors and shareholders of corporate clients
• Introducers and business partners where applicable
• Employees, contractors, and service providers where applicable
• All accounts opened with Apexx Capital
• All deposits and withdrawals
• All trading platform activity
• All website and client area activity
• All communications with Apexx Capital

The Company may apply additional procedures, restrictions, or checks based on client risk, country risk, payment method, account activity, transaction size, source of funds, source of wealth, trading behaviour, or other risk factors.

Apexx Capital applies a risk-based approach to AML, CFT, sanctions, fraud prevention, and payment monitoring.

This means that the Company may apply different levels of checks depending on the assessed risk of the Client, account, transaction, jurisdiction, payment method, or activity.

Risk factors may include:

• Country of residence
• Nationality
• Citizenship
• Tax residency
• Occupation
• Business activity
• Source of funds
• Source of wealth
• Payment method
• Deposit size
• Withdrawal size
• Transaction frequency
• Trading behaviour
• Use of multiple accounts
• Use of VPNs or masked IP addresses
• Connection to high-risk jurisdictions
• Politically exposed person status
• Sanctions exposure
• Adverse media
• Inconsistent information
• Suspicious or unusual account activity

The Company may classify clients as low, medium, or high risk based on internal procedures.

High-risk clients may be subject to enhanced due diligence, senior review, additional monitoring, payment restrictions, or account refusal.

Before opening or fully activating an account, Apexx Capital may require the Client to complete customer due diligence.

The Company may request information and documents including:

• Full legal name
• Date of birth
• Nationality
• Country of residence
• Residential address
• Email address
• Phone number
• Government-issued identification
• Proof of address
• Tax residency information
• Payment method verification
• Occupation
• Employment details
• Business activity
• Source of funds
• Source of wealth
• Expected account activity
• Expected deposit and withdrawal amounts
• Other information required for verification or compliance purposes

The Company may refuse to open an account, restrict account access, delay transactions, or close an account if the Client fails to provide requested information or documents.

Apexx Capital may verify the identity of individual clients using one or more of the following:

• Passport
• National identity card
• Driver's licence
• Residence permit
• Selfie or liveness check
• Video verification
• Electronic identity verification
• Third-party verification providers
• Sanctions and PEP screening
• Database checks
• Manual document review

The Company may reject documents that are expired, unclear, altered, inconsistent, incomplete, suspicious, unverifiable, or otherwise unacceptable.

The Company may request updated documents at any time.

Apexx Capital may request proof of residential address. Acceptable proof of address may include:

• Utility bill
• Bank statement
• Government correspondence
• Tax document
• Residence certificate
• Official address document
• Other documents accepted by the Company

Documents must usually show the Client's full name, residential address, issue date, and issuing entity.

The Company may reject documents that are too old, incomplete, edited, unclear, unverifiable, or inconsistent with other information.

Where the Client is a legal entity, Apexx Capital may request corporate documents and information including:

• Certificate of incorporation
• Company registration extract
• Articles of association
• Memorandum of association
• Register of directors
• Register of shareholders
• Ownership structure chart
• Proof of registered address
• Proof of operating address
• Board resolution
• Authorised signatory list
• Director identification documents
• Shareholder identification documents
• Ultimate beneficial owner identification documents
• Business activity description
• Source of funds
• Source of wealth
• Expected account activity
• Website and business materials
• Tax information
• Additional documents required for corporate verification

The Company may require identification and verification of all relevant directors, shareholders, authorised representatives, and ultimate beneficial owners.

For corporate clients, Apexx Capital may identify and verify ultimate beneficial owners.

A beneficial owner may include any person who directly or indirectly owns or controls a legal entity, exercises control over management, or benefits from the account.

The Company may refuse to onboard or continue servicing a corporate client if beneficial ownership is unclear, hidden, nominee-based, unverifiable, or considered high risk.

The Client must immediately notify the Company of any change in beneficial ownership, control, directors, authorised representatives, or corporate structure.

Apexx Capital may apply enhanced due diligence where the Client, account, transaction, jurisdiction, payment method, or activity is considered higher risk.

Enhanced due diligence may include:

• Additional identity verification
• Additional proof of address
• Source of funds documentation
• Source of wealth documentation
• Bank statements
• Payslips
• Tax documents
• Business records
• Corporate documents
• Contracts or invoices
• Proof of sale of assets
• Inheritance documents
• Investment statements
• Information about expected activity
• Information about trading purpose
• Senior compliance review
• Ongoing enhanced monitoring
• Restrictions on payment methods
• Restrictions on withdrawals
• Additional account approval steps

Enhanced due diligence may be applied before onboarding, before deposits, before withdrawals, during account review, or at any time during the business relationship.

Apexx Capital may request evidence showing where the funds used for deposits originate. Acceptable source of funds evidence may include:

• Bank statements
• Payslips
• Employment income records
• Business income records
• Company financial statements
• Sale agreement
• Property sale documents
• Investment account statements
• Dividend records
• Loan agreement
• Inheritance documents
• Gift declaration
• Crypto transaction records where applicable
• Tax documents
• Other documents accepted by the Company

The Company may reject, delay, return, or restrict funds where the source of funds is unclear, unsupported, inconsistent, suspicious, or unacceptable.

Apexx Capital may request evidence explaining how the Client accumulated their overall wealth. Source of wealth information may include:

• Employment history
• Business ownership
• Investment history
• Property ownership
• Inheritance
• Sale of business
• Sale of assets
• Savings history
• Professional income
• Dividend income
• Other lawful wealth sources

The Company may request supporting documentation where required by internal risk procedures.

Failure to provide sufficient source of wealth information may result in account restriction, refusal, or closure.

Apexx Capital may screen clients, beneficial owners, directors, shareholders, representatives, and connected persons for politically exposed person status.

A politically exposed person may include a person who holds or has held a prominent public function, as well as certain family members or close associates.

Where a Client is identified as a politically exposed person, or connected to one, the Company may apply enhanced due diligence, senior review, additional monitoring, and source of wealth checks.

The Company may refuse or terminate a relationship with a politically exposed person where the risk is considered unacceptable.

Apexx Capital may screen clients, beneficial owners, directors, shareholders, authorised representatives, transactions, payment methods, countries, IP addresses, and counterparties against applicable sanctions lists.

The Company may reject onboarding, suspend accounts, freeze activity, delay payments, reject withdrawals, close accounts, or report activity where sanctions risk is identified.

The Client must not use the services if they are subject to sanctions or acting on behalf of a sanctioned person, entity, country, organisation, or restricted party.

The Company may take any action it considers necessary to comply with sanctions obligations, payment provider requirements, banking requirements, or internal sanctions procedures.

Apexx Capital may restrict or prohibit clients from certain countries, territories, regions, or jurisdictions.

The Company may consider a jurisdiction restricted or high risk due to:

• Sanctions
• AML/CFT risk
• Regulatory restrictions
• Fraud levels
• Payment provider restrictions
• Banking limitations
• Legal uncertainty
• Internal policy
• Reputational risk
• Operational risk
• Terrorist financing risk
• Corruption risk
• Tax transparency concerns

The Company may update its restricted jurisdictions list at any time without prior notice.

The availability of the website in a country does not mean that services are authorised, approved, legal, or available in that country.

The Client is responsible for ensuring that using the services is lawful in their jurisdiction.

Apexx Capital may refuse or terminate relationships with clients who:

• Fail verification
• Provide false or misleading information
• Use stolen or fake documents
• Use third-party payment methods without approval
• Use nominee arrangements without disclosure
• Are subject to sanctions
• Are connected to prohibited jurisdictions
• Are involved in illegal activity
• Are suspected of fraud
• Are suspected of money laundering
• Are suspected of terrorist financing
• Are suspected of market abuse
• Are involved in chargeback abuse
• Use the account for another person
• Refuse to provide required documents
• Present unacceptable AML, sanctions, fraud, legal, or reputational risk

The Company is under no obligation to provide services to any person or entity.

Apexx Capital prohibits transactions involving:

• Funds from unlawful activity
• Stolen funds
• Fraud proceeds
• Drug trafficking proceeds
• Human trafficking proceeds
• Corruption proceeds
• Terrorist financing
• Sanctions evasion
• Tax evasion
• Illegal gambling proceeds
• Stolen payment cards
• Third-party funds without approval
• Money mule activity
• Layering or structuring activity
• False invoices
• Fake documents
• Shell companies used to hide ownership
• High-risk crypto activity where applicable
• Any activity considered suspicious, illegal, abusive, or unacceptable by the Company

The Company may reject, delay, reverse, restrict, investigate, or report prohibited or suspicious transactions.

The Client may deposit funds only through payment methods accepted by the Company.

Deposits must generally come from a payment account held in the Client's own name.

The Company may reject or return deposits where:

• The payment account is not in the Client's name
• The payment source cannot be verified
• The source of funds is unclear
• The deposit is from a third party
• The payment method is suspicious
• The payment is linked to fraud or chargeback risk
• The payment is linked to a restricted jurisdiction
• The payment creates AML, sanctions, legal, banking, or payment provider concerns
• The Client has not completed verification
• The Company requires further documents

Third-party deposits are not accepted unless expressly approved by the Company in writing.

Withdrawals are subject to verification, available balance, open positions, margin requirements, account status, payment provider rules, AML checks, security checks, and internal risk procedures.

The Company may delay, reject, reduce, or request additional information before processing a withdrawal where:

• Verification is incomplete
• The withdrawal method does not match the deposit method
• Payment ownership is unclear
• There is suspected fraud
• There is suspected money laundering
• There is suspected terrorist financing
• There is sanctions risk
• There is chargeback risk
• There is account misuse
• There is market abuse suspicion
• There is inconsistent account activity
• There is a pending compliance review
• There is a payment provider review
• There is an unresolved dispute
• There are unpaid fees or negative balances
• The withdrawal may breach applicable law or internal policy

The Company may return funds to the original payment source where required or appropriate.

The Company shall not be required to process a withdrawal until all required AML, KYC, payment, security, and compliance checks are complete.

Apexx Capital generally does not accept deposits or process withdrawals involving third-party payment accounts.

A third-party payment may include a payment made from or to a bank account, card, wallet, crypto wallet, payment provider account, or other payment method not held in the Client's own name.

The Company may reject, return, hold, or review third-party payments.

Where third-party payments are approved, the Company may require additional documents from the Client and the third party.

The Company may refuse third-party payments at its sole discretion.

Apexx Capital may require verification of payment methods. The Company may request:

• Bank statement
• Card ownership confirmation
• Payment provider screenshot
• Wallet ownership evidence
• Transaction confirmation
• Deposit receipt
• Withdrawal account verification
• Additional payment documents

The Company may reject or delay payment processing if payment ownership cannot be verified.

Apexx Capital may monitor deposits, withdrawals, trading activity, login activity, communication patterns, payment behaviour, and account behaviour.

Monitoring may be manual, automated, or semi-automated. The Company may monitor for:

• Unusual deposit patterns
• Unusual withdrawal patterns
• Rapid movement of funds
• Deposits followed by immediate withdrawal requests
• Multiple accounts
• Shared devices or IP addresses
• VPN or proxy use
• High-risk jurisdictions
• Third-party payments
• Inconsistent account activity
• Large transactions
• Structuring or splitting transactions
• Payment method changes
• Chargeback indicators
• Market abuse indicators
• Suspicious trading behaviour
• Fraud indicators
• Sanctions exposure
• Use of false documents
• Unusual source of funds
• Use of business accounts for personal accounts
• Use of personal accounts for business clients

The Company may request additional information or documents based on transaction monitoring results.

Apexx Capital may treat activity as suspicious if it appears inconsistent with the Client's profile, expected activity, source of funds, trading behaviour, payment history, jurisdiction, or account purpose.

Suspicious activity may include:

• False or inconsistent information
• Refusal to provide documents
• Use of fake or altered documents
• Use of third-party payment methods
• Large unexplained deposits
• Frequent deposits and withdrawals without trading activity
• Immediate withdrawal after deposit
• Multiple accounts using similar details
• Use of different names across payment methods
• Unusual IP or location activity
• Connection to high-risk jurisdictions
• Unexplained source of funds
• Unusual corporate structures
• Nominee ownership
• Use of shell companies
• Chargebacks or payment disputes
• Market abuse
• Suspicious digital asset activity
• Use of anonymising tools
• Sanctions-related indicators
• Any activity that the Company considers suspicious, abusive, fraudulent, illegal, or high risk

The Company may investigate suspicious activity and may take action in accordance with this Policy and the Terms and Conditions.

Where required or appropriate, Apexx Capital may report suspicious activity, suspected money laundering, suspected terrorist financing, sanctions concerns, fraud, or other unlawful activity to the relevant financial intelligence unit, law enforcement authority, court, regulator, payment provider, bank, compliance provider, or other competent authority.

The Company may disclose Client information, documents, transaction records, communication records, trading records, payment details, account records, device data, and other relevant information where required or permitted.

The Company may make such reports without notifying the Client.

The Company is not liable for disclosures made in good faith for AML, CFT, sanctions, fraud prevention, legal, compliance, payment, or security purposes.

The Client acknowledges that the Company may be legally or contractually restricted from disclosing certain information about AML, CFT, sanctions, fraud, compliance, payment, or security reviews.

The Company may not be able to inform the Client whether a suspicious activity report, sanctions report, internal investigation, payment review, or regulatory disclosure has been made or is being considered.

The Company may delay or refuse to provide explanations where doing so could compromise an investigation, breach law, breach payment provider requirements, or create financial crime risk.

Apexx Capital may suspend, restrict, freeze, terminate, or close any Client account, transaction, payment, withdrawal, platform access, or service access where the Company suspects or identifies AML, CFT, sanctions, fraud, payment, legal, operational, or reputational risk.

The Company may take actions including:

• Suspending account access
• Restricting trading
• Rejecting deposits
• Delaying withdrawals
• Requesting additional documents
• Closing open positions
• Cancelling pending transactions
• Freezing account activity
• Returning funds to original payment source
• Terminating the account
• Reporting activity to relevant parties
• Retaining records
• Deducting lawful fees, losses, chargebacks, or amounts owed

The Company shall not be liable for losses arising from lawful actions taken under this Policy or the Terms and Conditions.

This section does not give the Company the right to permanently retain funds lawfully due to the Client without lawful basis.

Where digital asset instruments, crypto-related payments, blockchain transfers, crypto wallets, or virtual asset exposure are used or supported, Apexx Capital may apply additional AML, sanctions, fraud, and blockchain risk controls.

The Company may review:

• Wallet ownership
• Blockchain transaction history
• Source of crypto funds
• Blockchain analytics results
• Exposure to mixers or tumblers
• Exposure to darknet markets
• Exposure to sanctioned wallets
• Exposure to stolen funds
• Exposure to scams or fraud
• Exposure to high-risk exchanges
• Use of privacy coins
• Unusual wallet activity
• Cross-chain movement
• Large or rapid transfers

The Company may reject, freeze, delay, review, return, or report crypto-related activity where the risk is unacceptable.

The Company may refuse to process digital asset-related transactions at its discretion.

Apexx Capital may use third-party service providers to support AML, KYC, sanctions screening, fraud prevention, payment verification, blockchain analytics, document verification, transaction monitoring, and compliance review.

Such providers may include:

• Identity verification providers
• Document verification providers
• KYC providers
• AML screening providers
• Sanctions screening providers
• PEP screening providers
• Adverse media providers
• Payment processors
• Banks
• Card networks
• Blockchain analytics providers
• Trading platform providers
• Technology providers
• Compliance consultants
• Legal advisers

The Company may rely on information, reports, results, risk scores, and recommendations from such providers.

The Company remains entitled to make final onboarding, payment, withdrawal, restriction, or account closure decisions based on its own internal procedures.

Apexx Capital may retain records relating to AML, KYC, CFT, sanctions, fraud prevention, payment processing, account activity, trading activity, communications, and compliance reviews.

Records may include:

• Identity documents
• Proof of address
• Corporate documents
• Beneficial ownership records
• Source of funds documents
• Source of wealth documents
• Payment records
• Deposit records
• Withdrawal records
• Trading records
• Communication records
• Compliance notes
• Risk assessments
• Screening results
• Suspicious activity records
• Reports made to relevant authorities or providers
• Internal decisions
• Account closure records

Records may be retained after account closure where required or permitted for legal, AML, CFT, sanctions, fraud prevention, tax, accounting, payment, audit, dispute resolution, or internal risk purposes.

Personal data collected for AML, KYC, CFT, sanctions, fraud prevention, payment verification, and compliance purposes will be processed in accordance with the Company's Privacy Policy.

The Client acknowledges that certain personal data is necessary for compliance and account operation.

Failure to provide required personal data or documents may result in refusal, restriction, suspension, or closure of the account.

The Company may share personal data with third parties where required or permitted for AML, CFT, sanctions, fraud prevention, payment, security, legal, compliance, or risk purposes.

Apexx Capital may maintain internal controls designed to support compliance with this Policy. Such controls may include:

• Internal AML procedures
• Client onboarding procedures
• Document review procedures
• Risk assessment procedures
• Transaction monitoring procedures
• Escalation procedures
• Suspicious activity review procedures
• Sanctions screening procedures
• Recordkeeping procedures
• Restricted jurisdiction controls
• Payment review controls
• Account restriction procedures
• Staff training where applicable
• Periodic policy review
• Use of third-party compliance tools

Access to AML and compliance information may be limited to authorised personnel and service providers.

The Company may designate an internal compliance contact, external compliance adviser, or responsible officer to oversee AML, KYC, sanctions, fraud prevention, and financial crime procedures.

The responsible person or team may be responsible for:

• Reviewing high-risk accounts
• Approving enhanced due diligence
• Reviewing suspicious activity
• Maintaining internal records
• Coordinating with service providers
• Reviewing AML controls
• Handling escalations
• Supporting reporting where required
• Updating procedures
• Maintaining restricted jurisdiction controls

Compliance responsibility may be managed internally or with assistance from external advisers and service providers.

Where applicable, Apexx Capital may provide relevant personnel, contractors, or service providers with training or guidance on AML, CFT, sanctions, fraud prevention, KYC, suspicious activity, data protection, payment risk, and internal escalation procedures.

Training may be provided periodically and may be updated based on changes in business activity, legal requirements, risk exposure, payment methods, platform features, or internal procedures.

The Client agrees to cooperate fully with Apexx Capital's AML, KYC, CFT, sanctions, payment, fraud prevention, and compliance procedures.

The Client must:

• Provide accurate information
• Provide complete documents
• Respond to requests within a reasonable timeframe
• Notify the Company of changes to personal information
• Use only approved payment methods
• Avoid third-party payments unless approved
• Provide source of funds evidence where requested
• Provide source of wealth evidence where requested
• Avoid prohibited activity
• Comply with applicable law
• Comply with this Policy and the Terms and Conditions

Failure to cooperate may result in account refusal, restriction, payment delay, withdrawal rejection, account closure, or reporting where required or appropriate.

The Client must not provide false, misleading, incomplete, altered, forged, stolen, or fraudulent information or documents.

If the Company suspects that information or documents are false, misleading, altered, forged, stolen, or fraudulent, the Company may:

• Reject the account application
• Suspend the account
• Restrict trading
• Delay withdrawals
• Reject payments
• Close open positions
• Terminate the account
• Retain records
• Report activity where required or appropriate
• Take legal action
• Share information with payment providers, banks, authorities, service providers, or legal advisers where permitted

Apexx Capital may update, amend, replace, or modify this Policy at any time. Updates may reflect changes in:

• Legal requirements
• AML standards
• Payment provider requirements
• Banking requirements
• Platform operations
• Internal procedures
• Fraud risks
• Sanctions risks
• Business operations
• Available services
• Jurisdiction restrictions

The updated version will be published on the website with a revised "Last Updated" date.

Continued use of the website, platform, client area, account, or services after publication of an updated Policy constitutes acknowledgement of the updated Policy.

The Client is responsible for reviewing this Policy regularly.

If you have questions about this AML/CFT Policy, you may contact:

By opening an account, accessing the website, using the platform, submitting documents, making deposits, requesting withdrawals, communicating with the Company, or continuing to use the services, the Client acknowledges and agrees that:

• They have read and understood this Policy.
• They will comply with AML, KYC, CFT, sanctions, fraud prevention, payment, and compliance procedures.
• They will provide accurate and complete information.
• They will provide requested documents.
• They will not use the services for money laundering, terrorist financing, sanctions evasion, fraud, or unlawful activity.
• They understand that the Company may delay, reject, restrict, suspend, review, or terminate accounts and transactions for AML, CFT, sanctions, fraud, payment, compliance, or risk reasons.
• They understand that the Company may report suspicious activity where required or appropriate.
• They understand that the Company may retain records and share information where required or permitted.
• They understand that failure to cooperate may result in refusal, restriction, suspension, or closure of the account.