Anti-Money Laundering Policy

01Our Commitment

PROFISTRA ("Company") is committed to full compliance with applicable anti-money laundering (AML), counter-terrorist financing (CTF), and anti-fraud laws and regulations. We recognise that financial crime poses serious risks to the integrity of the global financial system and the safety of our users.

This policy outlines the measures PROFISTRA takes to detect, prevent, and report suspicious financial activity. All users of the PROFISTRA platform are required to act in accordance with this policy as a condition of using our Services.

Our AML programme is administered by a designated Compliance Officer who holds responsibility for overseeing implementation, monitoring, training, and reporting.

02Customer Due Diligence (CDD)

PROFISTRA applies risk-based customer due diligence measures. All users are subject to baseline verification at registration. Enhanced due diligence (EDD) is triggered in higher-risk scenarios.

Standard CDD includes:

• Collection of email address, name, and account creation date at registration;
• Validation that the email domain is not associated with known disposable or fraudulent services;
• IP geolocation screening against restricted jurisdiction lists.

Enhanced Due Diligence (EDD) may be triggered when:

• A withdrawal request exceeds a defined high-value threshold;
• Account activity is inconsistent with the user's stated profile;
• Automated monitoring systems flag unusual patterns;
• A user is identified as a politically exposed person (PEP).

When EDD is triggered, we may request government-issued identity documents, proof of source of funds, or other verification materials before processing the transaction. Failure to provide requested documentation will result in suspension of the relevant transaction.

03Transaction Monitoring

PROFISTRA operates automated transaction monitoring to identify patterns or behaviours that may indicate money laundering or financial crime. Monitoring focuses on:

• Unusually large or rapid deposits followed by immediate withdrawal requests;
• Multiple accounts sending funds to a single withdrawal address;
• Deposit addresses previously associated with known illicit activity (identified via blockchain analytics tools);
• Transactions structured in a manner designed to avoid reporting thresholds (structuring);
• Unusual referral commission patterns that suggest coordinated abuse.

Flagged transactions are reviewed by the compliance team. Transactions under review will be held pending and the user notified where doing so does not compromise the integrity of any investigation.

04Prohibited Activities

The following activities are strictly prohibited on the PROFISTRA platform:

• Using PROFISTRA to launder proceeds of crime or convert illicitly-obtained funds;
• Depositing funds on behalf of a third party without disclosure;
• Using cryptocurrency mixing, tumbling, or privacy coin bridge services to obscure the origin of funds prior to deposit;
• Providing false identity information during registration or verification;
• Funding an account using funds derived from terrorism, human trafficking, drug trafficking, or any other criminal enterprise;
• Using the platform in any manner that assists in the circumvention of applicable AML laws.

Accounts found to be in violation of this section will be permanently suspended, funds will be frozen pending investigation, and the matter may be reported to relevant law enforcement authorities.

05Sanctions Screening

PROFISTRA screens users and transactions against international sanctions lists, including those maintained by:

• The Office of Foreign Assets Control (OFAC), United States;
• The European Union consolidated sanctions list;
• The United Nations Security Council consolidated list;
• The Financial Crimes Enforcement Network (FinCEN) list.

Users or transactions matching sanctions designations will be immediately blocked. Accounts associated with sanctioned individuals or entities will be suspended and reported to the relevant authorities. We do not accept users from OFAC-embargoed countries or jurisdictions.

06Reporting Obligations

Where legally required, PROFISTRA will file Suspicious Activity Reports (SARs) or equivalent filings with the relevant financial intelligence unit (FIU) in the applicable jurisdiction. We are legally prohibited from disclosing to the subject of a SAR that a report has been filed ("tipping off" prohibition).

PROFISTRA will co-operate fully with competent authorities including law enforcement, financial regulators, and judicial bodies in the course of any investigation involving our platform or its users.

07Record Keeping

PROFISTRA maintains records of all customer due diligence information, transaction records, and compliance-related documentation for a minimum of 5 years from the date of the transaction or account closure, as required by applicable AML regulations. These records are maintained securely and are made available to competent authorities upon lawful request.

For AML-related enquiries, contact our Compliance team at support@profistrafunds.com with the subject line "AML Enquiry".