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Anti-Money Laundering Policy

Last updated: May 12, 2026

Contents
1. Introduction 2. Compliance Framework 3. User Verification 4. Transaction Monitoring 5. Suspicious Activity 6. Record Keeping 7. Enforcement

1. Introduction

AgoraDesk is committed to preventing the use of its platform for money laundering, terrorist financing, fraud, and other unlawful activity.

This AML Policy describes the measures AgoraDesk may use to identify and address suspicious activity, manage financial crime risks, and cooperate with applicable legal and regulatory requirements.

Our approach is based on the nature of the platform, the risks associated with P2P trading, and the requirements that apply to our services in the jurisdictions where we operate.

SCOPE Platform activity

This policy applies to activity on the AgoraDesk platform that may present financial crime risks.

METHOD Risk-based approach

We assess risks based on factors such as transaction activity, account behavior, jurisdiction, and other relevant signals.

OUTCOME Preventing misuse

Our goal is to detect and address suspicious activity while allowing legitimate users to use the marketplace.

2. Compliance Framework

AgoraDesk takes a risk-based approach to financial crime prevention. Our compliance measures are designed around the nature of the platform, the activity taking place on it, and the legal requirements that apply to our services.

  • Risk-based assessment of platform activity
  • Review of activity that may indicate financial crime risks
  • Measures to address suspicious or prohibited activity
  • Record-keeping where required by applicable law
  • Cooperation with competent authorities where legally required
  • Regular review of our compliance procedures
01
Identify risk

We assess factors such as account activity, transaction patterns, payment methods, and geographic exposure.

02
Review activity

Activity that raises financial crime concerns may be reviewed using relevant account, trade, and transaction information.

03
Act proportionally

Depending on the circumstances, actions may include requesting additional information, limiting activity, or taking other steps required by applicable law.

3. User Verification

AgoraDesk does not require platform-wide KYC for every user. Verification may be requested where required by applicable law, based on specific risk factors, or as part of a trader's own trading requirements.

Verification may include:
  • Government-issued identification
  • Proof of address or residency
  • Source of funds or source of wealth information
  • Additional information required to assess a specific risk

Verification requirements may vary depending on the circumstances of a trade, the user's activity, applicable legal requirements, or the requirements of an individual trader.

Users who do not provide requested information may have certain activities restricted or their account may be suspended where permitted or required by applicable rules.

Risk-based does not mean arbitrary.

Verification requests are based on relevant risk factors such as unusual activity, transaction size, sanctions exposure, payment patterns, or other indicators that may require additional review.

4. Transaction Monitoring

AgoraDesk may review platform activity to identify patterns that could indicate money laundering, fraud, sanctions violations, or other financial crime risks.

Relevant risk indicators may include:

  • Activity involving sanctioned individuals or jurisdictions
  • Unusual transaction patterns or rapid changes in activity
  • Transactions that do not match the expected account or trade activity
  • Unusual payment instructions or payment behavior
  • Repeated cancelled or disputed trades
  • Other activity that may require additional review

Activity that raises concerns may be reviewed further and may result in requests for additional information, restrictions on activity, or other measures where required by applicable law.

Signal Typical review
Repeated cancelled trades Review of trading patterns and account activity
Unusual payment behavior Review of payment and trade details
High-risk jurisdiction exposure Additional risk and sanctions checks

5. Suspicious Activity Reporting

AgoraDesk is committed to reporting suspicious activity to the appropriate authorities where required by applicable law. When we identify activity that may be related to money laundering, terrorist financing, fraud, or other criminal activity, we may take appropriate action and cooperate with relevant authorities.

What We Report:
  • Activity involving sanctioned parties
  • Evidence of attempts to evade applicable reporting requirements
  • Transactions inconsistent with expected account activity
  • Other indicators of potential criminal activity

Reports are prepared with relevant evidence, timestamps, account identifiers, trade metadata, and available communication records. We do not notify users when doing so would be prohibited by law or could compromise an investigation.

6. Record Keeping

AgoraDesk keeps records of platform activity and other information where necessary to operate the service, investigate disputes, maintain security, or meet applicable legal requirements.

The type and retention period of records may vary depending on the nature of the information, the purpose for which it was collected, and applicable legal requirements.

Records may include:

  • Account and trade information
  • Trade and dispute records
  • Security and technical logs
  • Information required for legal or regulatory purposes
Records may be provided to competent authorities where required by applicable law.

7. Policy Enforcement

Violations of this AML Policy may result in actions appropriate to the circumstances and applicable legal requirements, including:

  • Account suspension or termination
  • Restrictions on trading activity
  • Requests for additional information or verification
  • Reporting to competent authorities where required by law
  • Other measures necessary to prevent misuse of the platform

Users with questions about this policy can contact AgoraDesk support through the available support channels.

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