Anti-Money Laundering (AML) Policy Effective Date: April 1, 2025

• Purpose

  This Anti-Money Laundering ("AML") Policy outlines the principles and procedures adopted by Vixor ("we," "our," or "us") to prevent and mitigate the risks of money laundering, terrorist financing, and other financial crimes through the use of its decentralized, non-custodial infrastructure platform ("Platform").

  Vixor operates as a Web3 infrastructure provider and does not engage in the custody, control, or management of user funds or assets. Nevertheless, we are committed to maintaining high ethical standards and supporting global efforts to combat illicit finance.

• Scope

  This AML Policy applies to all users of the Platform, as well as to any third parties, contributors, developers, or affiliates operating within or on behalf of Vixor. This Policy is designed in alignment with best practices outlined by the Financial Action Task Force (FATF), the European Union AML Directives, and guidance from international regulators.

• Non-Custodial Disclaimer

  Vixor does not provide custody, escrow, or account-based services. Users access the Platform solely through non-custodial blockchain wallets. As such, Vixor does not maintain user balances, receive or transmit funds on behalf of users, or control private keys.

  Given this structure, Vixor does not fall within the definition of a "financial institution" or "virtual asset service provider" (VASP) under many regulatory frameworks. However, we voluntarily adopt reasonable measures to discourage misuse of our technology.

• Risk-Based Approach

  While Vixor does not perform Know Your Customer (KYC) procedures due to its non-custodial and decentralized nature, we apply a risk-based approach, including:

  • Monitoring of wallet activity patterns via on-chain analytics tools
  • Blacklisting of wallet addresses associated with known illicit activity (e.g., OFAC sanctions lists, stolen funds, mixers)
  • Prohibiting interaction with the Platform from sanctioned jurisdictions or restricted territories
  • Flagging and reporting unusual or suspicious interactions where technically and legally feasible
• Prohibited Use

  The following uses of the Platform are strictly prohibited:

  • Engaging in transactions that violate AML, counter-terrorist financing (CTF), or anti-corruption laws
  • Facilitating the laundering of proceeds from criminal activity, including fraud, tax evasion, cybercrime, or narcotics
  • Interacting with the Platform from or on behalf of a person or entity subject to economic sanctions
  • Circumventing international AML/CTF regulations via anonymizing tools or chain-hopping
• Sanctions Screening

  Vixor uses third-party services and publicly available databases to screen blockchain wallet addresses and transactions against known sanctions lists, including but not limited to:

  • OFAC (U.S. Office of Foreign Assets Control)
  • United Nations Sanctions Lists
  • EU Sanctions List
  • UK HMT Consolidated List
  • Other international bodies and law enforcement databases.

  If a wallet address is found to be associated with prohibited activity, we may restrict its access to the Platform and, where appropriate, report the activity to competent authorities.

• Cooperation with Law Enforcement

  Vixor cooperates with lawful requests from regulatory and law enforcement agencies. If compelled by valid legal process, we may provide anonymized metadata or technical logs to the extent legally permissible and available.

  Due to our decentralized design and lack of user accounts, the scope of information we can share is inherently limited. Nevertheless, we remain committed to transparency and compliance with applicable legal obligations.

• Education and Awareness

  We promote awareness of AML/CTF risks across our team, contributors, and partners. This includes:

  • Internal review of AML risks in code design and smart contract deployment
  • Publicly disclosing our AML commitments via this policy
  • Avoiding integrations with third-party services that pose unmitigated AML risk
• Ongoing Review

  We regularly review and update this AML Policy to reflect evolving risks, regulatory changes, and industry best practices.

• Contact

  For questions regarding this AML Policy or to report suspicious activity, contact us at: compliance@vixor.io