Anti–Money Laundering Policy

1. Purpose & Commitment

Nexa Group is committed to maintaining a safe, transparent, and compliant financial ecosystem within Vexor. This AML Policy outlines the controls and procedures we use to safeguard users, prevent financial crime, and comply with global regulations, including (where applicable):

• EU Anti–Money Laundering Directives (AMLD)
• U.S. Bank Secrecy Act (BSA)
• FATF (Financial Action Task Force) international standards
• Local financial compliance and reporting requirements

Money laundering, fraud, and illicit financial activity are strictly prohibited on Vexor.

2. Scope of Covered Services

AML controls apply to all financial and value-transfer operations within Vexor, including:

• Virtual currency purchases (coins, credits, boosts)
• Virtual gifting and digital micro-transactions
• Creator payouts and earnings withdrawals
• Promotional purchases and subscription services
• Any feature where funds, credits, or assets change hands

Users participating in monetization or payout programs are subject to enhanced verification.

3. AML Risk Controls & Monitoring

Nexa Group employs layered detection systems, human review, and automated tools to identify suspicious or unlawful financial behavior. Core controls include:

• Transaction Monitoring: Automatic scanning for irregular patterns, rapid coin purchases, abnormal gift flows, or circular transactions.
• Fraud & Anomaly Detection: AI-based analysis of payment fraud, card chargeback risk, stolen card usage, and bot-driven financial activity.
• KYC/Identity Verification: Creators and payout recipients may be required to provide verified identity information (ID, tax details, address).
• Sanctions & Blacklist Screening: Users, payees, and payment sources may be checked against international sanctions lists and fraud databases.
• Withdrawal Controls: Limits on payout frequency, amount thresholds, and region-based restrictions to prevent laundering and structuring.
• Geolocation & IP Analysis: Flagging of suspicious use from high-risk areas, VPN abuse, or attempts to bypass regional restrictions.

These systems help ensure financial integrity and protect both users and creators.

4. Prohibited Financial Activities

The following activities are strictly forbidden and may result in immediate enforcement:

• Using Vexor to launder proceeds of crime through virtual gifts or currency
• Purchasing coins or credits using stolen credit cards or fraudulent payment methods
• Structuring payouts to avoid detection or financial oversight
• Using multiple accounts to disguise the origin or flow of funds
• Transferring funds on behalf of criminal organizations or sanctioned entities
• Abusing referral or promotional programs to obtain illicit financial gain
• Accepting or distributing payments linked to illegal goods, services, or activities

Vexor may suspend or terminate accounts involved in any prohibited financial activity.

5. Enforcement & Response Actions

If suspicious financial activity is detected, Nexa Group may take one or more actions:

• Freeze coins, balances, or creator earnings
• Delay or block withdrawals
• Require additional identity verification (KYC)
• Restrict or terminate user accounts
• Preserve financial data for regulatory review
• Report suspicious activity to law enforcement or financial authorities

Vexor fully cooperates with international financial crime investigations.

6. Reporting Suspicious Activity

Nexa Group may file Suspicious Activity Reports (SARs) or equivalent filings with:

• Financial intelligence units (FIUs)
• Local or national law enforcement
• Regulatory authorities overseeing financial compliance

We do not disclose to users whether a report has been filed.

7. User Responsibilities

All users must ensure their activities comply with applicable laws. You agree NOT to:

• Misrepresent your identity or payment information
• Use Vexor for any unlawful or deceptive financial purpose
• Create accounts to evade bans, limits, or verification requirements
• Participate in laundering schemes involving virtual currency

Users who violate these responsibilities may face account closure and legal reporting.

8. Policy Updates

AML regulations evolve regularly. Nexa Group may update this Policy to reflect:

• New legal requirements
• Changes in payment systems or monetization features
• Improved risk controls and fraud detection technologies

Continued use of Vexor after updates signifies acceptance of the revised Policy.

9. Contact Information

For AML compliance questions or financial security matters, contact:

Financial Compliance: finance@vexor.to
AML Officer: aml@vexor.to
Nexa Group Legal: legal@nexa-group.org