AML & KYC Policy

1. Purpose & Scope

This policy sets out the framework Veilon Trading ("Veilon", "we", "us", or "our") applies to prevent its services from being used for money laundering, terrorist financing, sanctions evasion, fraud, or other financial crime. It applies to all directors, officers, employees, contractors, and any third party acting on Veilon's behalf, and to all customers and transactions processed through the Veilon platform. Veilon Trading is a trading name of Black Box Research Ltd., a company registered in England & Wales (company no. 14223398), with its registered office at Threadneedle Place, Manchester, M46 0TW, United Kingdom.

Veilon is committed to conducting its business in accordance with applicable anti-money laundering and counter-terrorist financing ("AML/CTF") standards, including the principles of the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) ("MLR 2017"), the Proceeds of Crime Act 2002 ("POCA"), the Terrorism Act 2000, and applicable UK and international financial sanctions regimes.

2. Business Model & Regulatory Context

Veilon operates a simulated trading evaluation service. Customers pay a one-time service fee for access to a simulated ("demo") trading environment in which they attempt to meet defined performance and risk objectives. No orders are executed on live financial markets, no real customer capital is placed at risk, and Veilon does not hold, custody, or manage client money or client assets.

Accordingly, fees paid by customers are service fees, not deposits, investments, or client money, and confer no security, share, or interest in any fund or trading capital. Any payout to a successful customer is a discretionary Performance Reward paid by Veilon out of its own revenue and calculated by reference to simulated performance; it is not a return on investment, a profit share, a distribution, or wages.

Veilon does not provide regulated investment services, does not act as a broker, custodian, dealer, or financial intermediary, and does not solicit deposits. Notwithstanding that the service is simulated, Veilon applies the financial-crime controls in this policy on a risk-based basis to protect the integrity of its payment flows and payout process.

3. Risk-Based Approach

Veilon adopts a risk-based approach. Controls are calibrated to the money-laundering and terrorist-financing risk presented by a given customer, transaction, payment method, and geography. We periodically assess risk across customer, geographic, product/channel, and transaction factors. Higher-risk relationships are subject to Enhanced Due Diligence ("EDD") and senior sign-off.

4. Governance & The Nominated Officer (MLRO)

Veilon appoints a Nominated Officer (Money Laundering Reporting Officer, "MLRO") responsible for maintaining this policy, receiving internal suspicious-activity reports and deciding whether to report to the National Crime Agency ("NCA"), overseeing customer due diligence, sanctions screening, and ongoing monitoring, and staff training.

Concerns relating to financial crime, suspicious activity, or this policy should be directed to the Nominated Officer at compliance@veilontrading.com.

5. Customer Due Diligence (CDD) & KYC

Veilon performs identity verification ("KYC") through a regulated third-party verification provider. Verification is risk-based and is required, at minimum, before any Performance Reward payout is processed, and may be triggered earlier where risk indicators warrant. Standard CDD collects and verifies full legal name, date of birth, residential address, a government-issued photo identity document, and a liveness/biometric check confirming the customer matches the document.

Enhanced Due Diligence is applied to higher-risk customers — including Politically Exposed Persons ("PEPs"), customers connected to high-risk jurisdictions, or customers exhibiting unusual activity — and may include additional identity evidence, source-of-funds information, and senior management approval. Veilon will refuse to onboard, refuse to pay out, suspend, or terminate any relationship where required due diligence cannot be satisfactorily completed.

6. Sanctions & PEP Screening

Customers are screened against applicable sanctions lists (including UK HM Treasury / OFSI, EU, and UN consolidated lists) and PEP/adverse-media data as part of the verification process. Veilon will not establish or continue a relationship with, or make any payout to, a person or entity subject to applicable financial sanctions. Apparent matches are escalated to the Nominated Officer and, where required, reported to the relevant authority.

7. Prohibited & Restricted Jurisdictions

Veilon does not offer its services in jurisdictions where doing so would be unlawful, or to persons located in comprehensively sanctioned territories. Access controls and geolocation checks are used to enforce these restrictions, and customers are prohibited from using proxies, VPNs, or false information to circumvent them.

8. Source of Funds

Given the low-value, service-fee nature of purchases and the simulated model, source-of-funds enquiries are applied on a risk basis — in particular for high-value or high-frequency activity, inconsistent payment behaviour, or where EDD is triggered. Veilon may request documentary evidence of source of funds before processing a payout.

9. Payments, Crypto & Flow of Funds

The one-time evaluation fee is received by Veilon and becomes Veilon's own revenue on receipt; it is not client money held on the customer's behalf, is not segregated, and the customer acquires no security, share, or interest in any fund or trading capital. Payments are received and processed by regulated third-party payment service providers and payment processors (covering card, cryptocurrency, and e-money rails). Payout of Performance Rewards is funded from Veilon's own revenue and paid to the verified customer either directly in cryptocurrency or via a regulated third-party payments / contractor-payroll provider.

Crypto payments are accepted only through a regulated crypto payment processor. Veilon relies on the processor's own AML/KYC and travel-rule controls in addition to the controls in this policy, and reserves the right to decline, freeze, or reverse transactions that present financial-crime risk.

10. Ongoing Monitoring

Veilon monitors customer activity throughout the relationship for indicators of money laundering, fraud, account abuse, or platform exploitation — including mismatches between identity, payment, geolocation, and behavioural data; structuring of purchases or payouts; rapid purchase-and-payout cycles or coordinated multi-account activity; chargebacks and payment-instrument abuse; and behavioural risk signals surfaced by Veilon's internal scoring (VeilonScore). Activity that appears unusual or inconsistent with a customer's profile is escalated to the Nominated Officer for review.

11. Suspicious Activity Reporting & Tipping-Off

Any employee who knows or suspects, or has reasonable grounds to suspect, that a person is engaged in money laundering or terrorist financing must report it internally to the Nominated Officer without delay. The Nominated Officer assesses each report and, where appropriate, submits a Suspicious Activity Report to the NCA and seeks a Defence Against Money Laundering where required before proceeding.

Staff must not disclose to a customer or any third party that a report has been made or that an investigation may be taking place ("tipping-off"), as doing so may constitute a criminal offence.

12. Record Keeping

Veilon retains customer identification and verification records, transaction records, and records of any internal or external suspicious-activity reports for a minimum of five (5) years from the end of the customer relationship or the date of the relevant transaction, in line with MLR 2017, and longer where required by law or an ongoing investigation. Records are stored securely and made available to competent authorities on lawful request.

13. Training & Awareness

Relevant personnel receive AML/CTF awareness training appropriate to their role on induction and periodically thereafter, covering the risks the business faces, how to recognise suspicious activity, and how and to whom to report it.

14. Governance, Review & Updates

This policy is owned by the Nominated Officer and reviewed at least annually, and on any material change to Veilon's business, payment providers, applicable law, or risk profile. Veilon reserves the right to update this policy at any time; the current version is published on this page.

15. Contact

Financial-crime, AML, or KYC enquiries: compliance@veilontrading.com. General support: support@veilontrading.com.