Anti-Money Laundering (AML) Policy

1. Our Commitment

Vertex Trading E-Commerce LLC is committed to conducting business with integrity and in compliance with applicable anti-money laundering (AML) and counter-terrorist financing (CTF) laws and regulations in the jurisdictions in which we operate, including Uzbekistan, the United Kingdom and the United Arab Emirates. This policy sets out the framework we apply to identify, prevent and report suspected money laundering or financial crime in connection with our business.

2. Scope

This policy applies to all payments received by Vertex Trading LLC for software development and technology services, all client relationships, and all employees, contractors and representatives who handle client onboarding, contracts or payments on our behalf.

3. Client Due Diligence

Before entering into a service engagement or accepting payment, we undertake due diligence proportionate to the size, nature and risk profile of the engagement. This may include verifying the identity of the contracting business and its beneficial owners, confirming the legitimacy of the business and the source of funds, and screening against applicable sanctions and watch lists. Further detail on our client verification process is set out in our KYC Policy.

4. Risk-Based Approach

We apply a risk-based approach to AML compliance, meaning the level of due diligence applied scales with the assessed risk of a client relationship. Factors we consider include the client's jurisdiction, industry, ownership structure, payment method, transaction size and pattern, and whether the client or its principals are politically exposed persons (PEPs) or subject to sanctions.

5. Payment Monitoring

We monitor incoming payments for consistency with the contracted scope of work and invoiced amounts. We do not accept payment structures designed to obscure the origin of funds, payments from unrelated third parties without a clear, documented business justification, or cash payments above thresholds permitted under applicable law. Unusual payment patterns — such as payments significantly exceeding the value of contracted Services, requests for refunds to a different account or payment method than the original payment, or attempts to split payments to avoid reporting thresholds — are treated as red flags requiring enhanced review.

6. Sanctions Compliance

We do not knowingly engage in business relationships with individuals, entities or jurisdictions subject to applicable sanctions regimes, including those maintained by OFAC (U.S.), HM Treasury (UK), the EU, and the UN Security Council. Prospective clients are screened against relevant sanctions lists as part of onboarding.

7. Reporting Suspicious Activity

Where we identify activity that reasonably appears to be linked to money laundering, terrorist financing or other financial crime, we will decline or terminate the relevant engagement, and, where legally required, report the activity to the relevant financial intelligence unit or regulatory authority. Employees and contractors are required to escalate any concerns internally without alerting the client involved ("no tipping off"), consistent with applicable law.

8. Record Keeping

We retain client due diligence records, engagement contracts and payment records for a minimum of five (5) years following the end of a client relationship, or longer where required by applicable law or regulation, in order to support audit, regulatory and law enforcement requirements.

9. Training

Employees and contractors involved in client onboarding, contracting or payment processing receive periodic training on recognizing and escalating potential money laundering or financial crime risks relevant to their role.

10. Policy Review

This policy is reviewed periodically and updated as necessary to reflect changes in applicable law, regulatory guidance, and our risk assessment.

11. Contact

Questions regarding this AML Policy, or reports of suspected financial crime concerning our business, can be directed to info@vertextradingsllc.com.