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Anti–Money Laundering (AML) and Anti-Fraud Policy

Last updated: November 29, 2025

1. Purpose and Scope

This Anti–Money Laundering and Anti-Fraud Policy (“AML Policy”) sets forth the general principles and guidelines of JOLDERS for the prevention, detection, and reporting of money laundering, terrorist financing, fraud, and other illicit activities in connection with the use of the Platform.

Although JOLDERS does not act as a financial institution, broker-dealer, or payment provider, and does not itself hold client funds or execute financial transactions on behalf of Users, JOLDERS is committed to preventing the misuse of the Platform for unlawful purposes.

2. Prohibited Uses

Users shall not use the Platform for any of the following activities:

  • Money laundering or attempts to disguise the origin of funds;
  • Financing of terrorism or proliferation of weapons of mass destruction;
  • Fraud, misrepresentation, or deception in relation to any person, entity, or authority;
  • Violation of economic or trade sanctions, including those administered by OFAC, the European Union, or the United Nations;
  • Any activity that would constitute a criminal offense in the applicable jurisdiction.

3. Risk-Based Approach

JOLDERS may apply a risk-based approach to monitor usage patterns, detect anomalous behavior, and identify potential misuse of the Platform. Monitoring may include, without limitation: access logs, activity patterns, IP analysis, volume of usage, and other indicators.

4. Know Your Customer (KYC) and Verification

JOLDERS reserves the right, at any time and in its sole discretion, to request identification information, documentation, or other evidence to verify the identity of Users or Organizations, their authorized representatives, or the nature of their activities in relation to the Platform.

Such information may include, for example, government-issued identification, corporate registration documents, proof of address, tax identification numbers, or similar data.

Failure or refusal to provide such information in a timely manner may result in suspension or termination of access to the Platform.

5. Monitoring and Reporting

JOLDERS may monitor Platform activity to detect patterns that could indicate fraud, abuse, or potential involvement in money laundering or terrorist financing. If JOLDERS reasonably suspects that any User or activity may be connected to unlawful conduct, JOLDERS may:

  • Immediately suspend or terminate the relevant Account(s);
  • Restrict access to certain features or Services;
  • Report the matter to competent authorities or regulatory bodies, as required or permitted by law;
  • Cooperate with law enforcement agencies, regulators, or other competent authorities.

6. Cooperation with Authorities

JOLDERS will cooperate, to the extent required or permitted by applicable law, with competent authorities in the investigation and prosecution of money laundering, terrorist financing, fraud, or other criminal or unlawful activity.

7. User Responsibilities

Users are responsible for ensuring that their use of the Platform complies with all applicable laws and regulations, including those related to money laundering, terrorist financing, sanctions, and financial crime. Users must not knowingly or negligently facilitate, assist, or participate in any unlawful activity through or in connection with the Platform.

8. No Liability for Third-Party Conduct

JOLDERS shall not be liable for any acts or omissions of Users or third parties who misuse the Platform for illegal purposes. To the maximum extent permitted by law, Users agree to indemnify and hold JOLDERS harmless from any claims, damages, or liabilities arising out of or relating to their unlawful or fraudulent use of the Platform.

9. Policy Review and Updates

JOLDERS may update this AML Policy from time to time to reflect changes in laws, regulations, or internal practices. Updated versions will be posted on https://jolders.com.

10. Contact

For questions regarding this AML Policy, you may contact JOLDERS at:
Email: aml@jolders.com
Address: 8 THE GREEN STE B, DOVER, DELAWARE 19901, USA