AML/KYC Compliance Policy

This Anti-Money Laundering and Know Your Customer Policy ("AML/KYC Policy") describes how Wealtii (operated by its founder, Zayd Ahmed) ("Wealtii", "we", "us", "our") works to prevent money laundering, fraud, and other financial crimes on our platform. We believe that strong security and clear identity verification protect everyone, from individual investors to the broader financial system. This Policy applies to all users who create an account, make transactions, or interact with Wealtii's services in any way. It should be read alongside our Terms of Service and Privacy Policy.

Protecting your investments starts with knowing who's on the platform. Our AML/KYC program is designed to: (a) verify users' identities in proportion to the amounts they transact; (b) prevent bad actors from using the platform for illicit purposes; (c) monitor transactions for unusual patterns; (d) keep records for transparency and accountability; and (e) cooperate with authorities when required by law. These measures create a safer environment for everyone and help build the trust that makes digital asset investing more accessible.

We take a risk-based approach informed by the Financial Action Task Force (FATF) recommendations: the more you transact, the more we verify. Smaller accounts start with email verification only, while larger or more complex activity requires identity documents and, in some cases, more information.

Wealtii is currently operated by its founder, Zayd Ahmed. A formal legal entity has not yet been established; we are working towards formal company registration. Wealtii is not registered or licensed as a broker-dealer, investment adviser, money services business (MSB) or virtual asset service provider (VASP) with any regulator (such as the SEC, FINRA or FCA), and it is not regulated. Card and bank purchases of USDT are handled by licensed third-party on-ramp providers. No regulator currently requires or supervises this Policy; we apply it voluntarily and will update it as our legal and regulatory status changes.

We review and update this Policy periodically to reflect evolving standards, new capabilities, and user feedback. When we make material changes, we'll notify you through the platform or via email. Continuing to use Wealtii after updates means you accept the revised Policy. By using our services, you agree to: (a) provide accurate, truthful information during registration and verification; (b) cooperate with our verification procedures and provide requested documentation promptly; (c) notify us of material changes to your personal information; (d) use the platform only for lawful purposes; and (e) consent to ongoing monitoring of your account activity.

Know Your Customer (KYC) is the process of verifying that you are who you say you are. It's a standard practice across the financial industry, and it serves several important purposes: (a) it prevents fraud and identity theft, keeping your account safe; (b) it stops criminals from misusing the platform; (c) it enables us to detect suspicious transaction patterns; and (d) it builds trust in the Wealtii community. Think of KYC as the lock on the front door. It's there to protect everyone inside.

No ID documents are needed to start: verify your email and you can invest up to $10,000. ID verification unlocks higher limits.

When you verify your email address, your account automatically receives the Basic level. Basic lets you deposit, buy, sell and withdraw up to $10,000 in total over the life of the account. To go above that, you complete identity verification: Intermediate (up to $100,000 per day) or Advanced (no platform limit). Every account is tied to a verified email address, so there are no anonymous accounts.

KYC isn't a one-time event. We may ask for updated or additional documents at any time, for example if your account activity changes significantly or your documents expire.

If you buy USDT by card or bank transfer through a third-party on-ramp provider, that provider runs its own identity checks under its own terms.

For the Intermediate and Advanced levels, you upload your documents through your account dashboard and Wealtii reviews them manually. We check each submission for clarity, authenticity and consistency with the information you gave when you registered. For the Intermediate level, we compare your selfie with your ID document. Documents are stored encrypted. We aim to review submissions within 24 to 48 hours and will email you the outcome.

We accept the following government-issued documents for identity verification:

Primary Identification (Photo ID): • Passport: valid and unexpired, from any recognized country • National Identity Card: government-issued with photo • Driver's License: government-issued with photo

Proof of Address (for Advanced Verification): • Utility bill (electricity, water, gas, internet): issued within the last 3 months • Bank statement from a recognized financial institution: issued within the last 3 months • Official government correspondence: issued within the last 3 months

All documents must be clear, legible, in color, and show the complete document without cropping or editing. The name on your documents must match your account registration. We may request alternative documentation if the initial submission doesn't meet our quality standards.

Wealtii uses three verification levels. Your account receives the Basic level automatically once you verify your email address, and you can upgrade at any time through your account dashboard. Higher levels require identity documents and unlock higher transaction limits:

• Basic: Automatic once you verify your email address. Documents: None. Limits: Up to $10,000 in total over the life of the account, separately for deposits, purchases, sales and withdrawals.
• Intermediate: Identity verification, reviewed manually. Documents: Government-issued photo ID (national ID card or driver's license) and a selfie holding it. Limits: Up to $100,000 per rolling 24 hours, separately for deposits, purchases, sales and withdrawals.
• Advanced: Enhanced verification, reviewed manually. Documents: Valid passport and proof of address dated within the last 3 months. Limits: No platform limit.

The Basic level is assigned automatically once you verify your email address and accept our Terms of Service and this Policy. No ID documents are needed.

What you can do with Basic Verification: • Deposit USDT into your account • Purchase index fund units • Sell index fund positions • Withdraw USDT to your wallet • View your portfolio, transaction history, and market data • Contact customer support

Transaction limits (lifetime aggregate per category): • Deposits: Up to $10,000 USD equivalent • Purchases: Up to $10,000 USD equivalent • Sales: Up to $10,000 USD equivalent • Withdrawals: Up to $10,000 USD equivalent

Each category (deposits, purchases, sales, withdrawals) is tracked separately. This means you could deposit up to $10,000 AND purchase up to $10,000. The limits don't combine across categories. ID verification (Intermediate or Advanced) unlocks higher limits.

Intermediate Verification raises your limit to $100,000 per rolling 24 hours for each type of transaction.

What you need: • A government-issued ID: National ID Card or Driver's License • A selfie holding your ID document

Transaction limits (per 24-hour rolling period, per category): • Deposits: Up to $100,000 USD equivalent per day • Purchases: Up to $100,000 USD equivalent per day • Sales: Up to $100,000 USD equivalent per day • Withdrawals: Up to $100,000 USD equivalent per day

Your documents are reviewed manually. We aim to complete reviews within 24 to 48 hours of submission.

Advanced Verification removes Wealtii's platform transaction limits. Limits set by third parties, such as on-ramp providers, may still apply.

What you need: • A valid, unexpired passport • Proof of residential address (utility bill, bank statement, or government letter dated within the last 3 months)

Transaction limits: • Deposits: No platform limit • Purchases: No platform limit • Sales: No platform limit • Withdrawals: No platform limit

Your documents are reviewed manually. We aim to complete reviews within 24 to 48 hours of submission. If your verification is denied at any level, we'll notify you by email with a general reason. You can appeal within 30 days by submitting additional documentation or addressing the concerns identified.

Enhanced Due Diligence (EDD) is additional verification that may be required for certain accounts or transactions that present higher risk. EDD is not a sign of wrongdoing. It's a standard practice across the financial industry. It simply means we need to learn a bit more about you or a specific transaction before proceeding. The vast majority of users will never encounter EDD, but it's important for us to have these processes in place to protect the platform and our entire user community.

We may apply Enhanced Due Diligence in situations such as:

• Transactions that are unusually large or frequent relative to your account profile
• Accounts with connections to jurisdictions identified as higher risk by international bodies like the FATF
• Situations where the source of funds cannot be easily explained or verified
• Transaction patterns that are inconsistent with your stated profile or typical activity
• Accounts flagged by our monitoring systems for further review
• Requests for transaction limits significantly above standard thresholds
• Customers who hold or have held prominent public positions (Politically Exposed Persons)

If EDD applies to you, we'll reach out with clear instructions on what additional information or documentation we need. We aim to make the process as smooth as possible.

If Enhanced Due Diligence is required, you may be asked to provide some or all of the following:

Source of Funds Documentation: • Bank statements showing where your deposited funds originate • Employment verification or proof of income • Documentation of asset sales, investments, or inheritance • Any other evidence demonstrating the lawful origin of your assets

Additional Identity Verification: • Additional identity documents beyond what your current level requires • More detailed personal background information

Ongoing Requirements: • Periodic updates to your documentation • Explanations for specific transactions when requested

Providing clear, complete documentation upfront helps speed up the review. If you're unable to provide requested EDD documentation within the timeframe given, your account may be temporarily restricted until the review is complete. EDD decisions are documented.

Wealtii monitors platform activity to detect potential misuse. Transaction limits for each verification level are enforced automatically on every deposit, purchase, sale and withdrawal, including cumulative totals over rolling periods, alongside rate limiting. Security-relevant account events are logged, and activity that looks unusual, such as an unusually large withdrawal, is reviewed manually by Wealtii. Monitoring is a condition of using the platform.

While we don't disclose our specific detection rules (to prevent circumvention), our monitoring is designed to identify patterns such as:

• Transaction volumes or frequency inconsistent with a user's profile
• Rapid movement of funds in and out of accounts with no clear purpose
• Attempts to split large transactions into smaller ones to stay below thresholds (known as "structuring")
• Sudden changes in account behavior after periods of inactivity
• Activity involving known high-risk indicators
• Transactions that appear inconsistent with a user's stated occupation or source of funds

When something is flagged, we review it. In most cases, there's a reasonable explanation and no action is needed. If we need additional information from you, we'll reach out directly. We may also review the addresses that deposits come from and withdrawals go to.

Transaction limits are enforced based on your verification level (see Section 3). Key things to know:

• Limits are tracked per action category — deposits, purchases, sales, and withdrawals are counted separately
• Basic limits are lifetime aggregates; Intermediate limits reset every 24 hours
• Advanced-verified users have no transaction limits
• Attempting to exceed your limits will result in the transaction being declined
• Deliberately structuring transactions to avoid limits is prohibited and may result in account termination
• We may apply additional controls to accounts flagged for higher risk

If you need higher limits, the fastest path is upgrading your verification level through your account dashboard. For special circumstances, contact support@wealtii.com and we'll work with you.

When we detect activity that may indicate money laundering, fraud, or other financial crimes, we may report it to the appropriate authorities, including through Suspicious Activity Reports (SARs) where applicable. A SAR may be filed when a transaction has no apparent lawful purpose, involves suspected proceeds of crime, appears designed to evade legal requirements, or shows patterns consistent with known financial crime methods. SAR filing is a critical part of the global fight against financial crime, and Wealtii takes this responsibility seriously. We may file SARs even for relatively small amounts if the circumstances suggest suspicious intent.

SAR filings are strictly confidential. It is a legal requirement in most jurisdictions that we do not inform customers or any other party that a SAR has been filed, is being prepared, or that an account is under investigation. This "no tipping off" rule exists to protect the integrity of law enforcement investigations. If your account experiences restrictions or delays related to a compliance review, we may not be able to provide specific reasons. This isn't meant to cause frustration. It's a legal obligation we must follow. We handle all compliance matters with discretion. Filing a SAR does not automatically mean your account will be closed. In many cases, the relationship continues with enhanced monitoring.

We look for indicators that may warrant further investigation. While the presence of any single indicator doesn't automatically mean suspicious activity, examples include:

Account & Behavior Indicators: • Providing false or inconsistent information during verification • Reluctance to answer questions about transaction purposes or source of funds • Frequent changes to personal details without clear reason • No apparent legitimate reason for using the platform • Appearing to act on behalf of an undisclosed third party

Transaction Indicators: • Activity inconsistent with stated occupation or income • Sudden large increases in transaction volume without explanation • Transactions structured just below reporting thresholds • Rapid fund movements in and out with no clear business purpose • Circular transactions or round-tripping of funds

If you notice anything suspicious about another user's activity, you can report it to support@wealtii.com. We take all reports seriously and investigate promptly.

Wealtii does not knowingly provide services to sanctioned persons or entities, or to residents of jurisdictions subject to comprehensive sanctions. When you register, you confirm that you are not resident in a restricted jurisdiction and not on a sanctions list (see our Terms of Service). Identity documents submitted for the Intermediate and Advanced levels are reviewed manually, and we may check customer information against publicly available sanctions lists. We plan to add further screening tools as the platform grows.

Wealtii is not available to residents of jurisdictions subject to comprehensive international sanctions, including but not limited to:

• Cuba
• Iran
• North Korea (DPRK)
• Syria
• Crimea, Donetsk, and Luhansk regions of Ukraine

Additional jurisdictions may be restricted based on updates from the United Nations, European Union, United States (OFAC), United Kingdom, and other sanctions authorities. We also apply enhanced scrutiny to users from jurisdictions identified by the FATF as having strategic deficiencies in their anti-money-laundering frameworks. The list of restricted jurisdictions changes as international sanctions evolve. If your jurisdiction becomes restricted after you've opened an account, you will be given the opportunity to withdraw your funds before access limitations take effect, unless prohibited by law.

Sanctions violations are taken very seriously worldwide and can result in severe penalties including substantial fines and criminal prosecution for both individuals and institutions. Any user who attempts to access Wealtii from a sanctioned jurisdiction, misrepresents their location or identity to evade restrictions, or facilitates transactions on behalf of sanctioned parties will have their account immediately terminated and any assets frozen. We will report confirmed violations to the relevant authorities and cooperate fully with any resulting investigations. If you're unsure whether your jurisdiction is restricted, please contact support@wealtii.com before creating an account.

Maintaining thorough records is both a legal requirement and a fundamental part of platform security. Wealtii keeps records of:

• Account registration information and verification documents
• All transaction records (deposits, purchases, sales, withdrawals) with timestamps and amounts
• Compliance documentation including review notes and verification decisions
• Communication records related to compliance inquiries
• Audit logs tracking account activity

These records enable us to support regulatory inquiries, protect users in the event of disputes, reconstruct transaction histories when needed, and maintain an audit trail. Records are stored encrypted, and access is restricted to authorised personnel.

Following industry standards aligned with the Financial Action Task Force (FATF) recommendations, Wealtii retains AML/KYC records for a minimum of seven (7) years from the date of the transaction or the date your account is closed, whichever is later. This retention period applies to identification documents, transaction records, and compliance documentation. After the retention period expires, records are securely destroyed. Account closure does not trigger immediate deletion of your data. The seven-year period begins at closure. This isn't about keeping data longer than necessary; it's about meeting the standards that protect both you and the platform.

Your compliance records are protected by multiple security layers:

• Encryption at rest and in transit
• Access restricted to authorised personnel
• Audit logging of administrative actions

Records may be shared with law enforcement, financial regulators, or other government authorities when required by law, court order, or in connection with financial crime investigations. We respond to such requests promptly and cooperate with legitimate inquiries. For more details on how we protect your personal information, please refer to our Privacy Policy.

Wealtii is currently run by its founder, Zayd Ahmed, who is responsible for this AML/KYC Policy. That includes reviewing verification documents, investigating flagged activity, making reporting decisions, maintaining this Policy and dealing with authorities when required, with the authority to restrict accounts, decline transactions or end customer relationships where necessary. For compliance inquiries, contact support@wealtii.com.

Our AML/KYC program is not static — it evolves as we grow. We continuously refine our processes based on:

• Regulatory guidance and industry standard updates
• Lessons learned from our monitoring and investigations
• Advances in verification and compliance technology
• User feedback and operational experience
• Changes in the financial crime threat landscape

As Wealtii grows, we plan to add more monitoring and screening tools and an independent review of our compliance program. We will update this Policy as each is introduced.

Our compliance program is built on a risk-based foundation, as recommended by the FATF. This means we tailor our verification requirements, monitoring intensity, and review frequency based on the level of risk presented by each customer, transaction type, and jurisdiction. Risk factors we consider include:

• Geographic location and jurisdictional risk
• Transaction volumes and patterns
• Verification level and documentation quality
• Source of funds clarity
• Any adverse information identified during review

This approach lets us allocate compliance resources efficiently. Standard accounts experience a smooth, fast process, while higher-risk situations receive the additional attention they require. The goal is maximum security with minimum friction for the vast majority of users.

By using Wealtii, you agree to:

• Provide truthful, accurate, and complete information during registration and verification
• Cooperate with KYC and Enhanced Due Diligence requests and provide documentation within requested timeframes
• Notify us promptly of any material changes to your personal information
• Use the platform only for lawful purposes, never for money laundering, fraud, sanctions evasion, or any other financial crime
• Not attempt to circumvent verification requirements, transaction limits, or monitoring controls
• Respond to our questions about specific transactions
• Consent to ongoing monitoring of your account activity

Failure to meet these obligations may result in account restrictions, transaction holds, or permanent account closure. In cases of suspected financial crime, assets may be frozen and the matter reported to authorities.

While AML/KYC regulations require us to collect and retain certain personal data, you have rights regarding your information under applicable data protection laws:

• Right to Access: You can request a copy of the personal information we hold about you
• Right to Correction: If your information is inaccurate or incomplete, you can request corrections
• Right to Data Portability: You can request your data in a portable, machine-readable format

Important limitations: The right to deletion (erasure) is limited by our legal obligation to retain AML/KYC records for seven years. We cannot delete records required for regulatory compliance, even after your account is closed. During ongoing investigations, records may be subject to legal hold and cannot be modified or deleted. For data-related requests, contact support@wealtii.com with verification of your identity. See our Privacy Policy for additional details.

Wealtii may restrict or terminate accounts when:

• Verification is incomplete or documentation doesn't meet quality standards
• Enhanced Due Diligence review is in progress
• Suspicious activity has been flagged for investigation
• A potential sanctions match is identified
• Law enforcement or regulatory authorities request it
• The user violates our Terms of Service or this Policy
• The user provides false, fraudulent, or misleading information

In most termination scenarios, you'll have the opportunity to withdraw your funds before the account is permanently closed. However, in cases involving suspected crimes, sanctions violations, or law enforcement requests, assets may be frozen pending investigation or legal proceedings. If you believe your account has been restricted in error, contact support@wealtii.com, though we may not be able to share specific details if confidentiality requirements apply.

Here's where Wealtii stands today:

• Wealtii is currently operated by its founder, Zayd Ahmed. A formal legal entity has not yet been established; we are working towards formal company registration.

• Wealtii is not registered or licensed as a broker-dealer, investment adviser, money services business (MSB) or virtual asset service provider (VASP) with any regulator (such as the SEC, FINRA or FCA), and it is not regulated. Card and bank purchases of USDT are handled by licensed third-party on-ramp providers.

• This AML/KYC Policy is applied voluntarily, based on the FATF recommendations. No regulator currently requires or supervises it.

• Transactions on Wealtii are made in USDT on BNB Smart Chain. Wealtii does not hold or pay out fiat currency; card and bank purchases of USDT go through third-party on-ramp providers.

• Your assets on Wealtii are not covered by deposit insurance, an investor-compensation scheme or crypto insurance.

For questions about verification, compliance, or anything related to this Policy:

Email: support@wealtii.com

What to include in your message: • Your full name and account email address • A clear description of your question or concern • Any relevant documentation or supporting information

Support is ticket-based and you can submit a request at any time. We typically send a first response within a few hours; complex compliance matters may take longer to resolve.

We can help with: • KYC verification questions and document requirements • Understanding your verification level and transaction limits • Guidance on Enhanced Due Diligence requests • General questions about our AML/KYC policies • Data access or correction requests (subject to legal limitations)

Due to confidentiality requirements, we cannot discuss details of ongoing investigations, SAR filings, or the specific reasons behind certain account restrictions.

If you suspect that someone is misusing Wealtii for money laundering, fraud, or other financial crimes, please report it immediately:

Email: support@wealtii.com

Include as much detail as possible: what you observed, when it happened, any users or transactions involved (if known), and any supporting information. All reports are taken seriously and investigated promptly. We maintain confidentiality for all reporters and accept anonymous reports. You may also report suspected financial crimes directly to law enforcement or financial crime authorities in your jurisdiction.

This AML/KYC Policy is effective as of October 21, 2026.

Policy Version: 1.1.0 Last Updated: October 21, 2026

Changes to this Policy will be posted on the platform and communicated via email when material. Continued use of Wealtii after updates constitutes acceptance of the revised Policy. For questions about specific provisions or previous versions, contact support@wealtii.com.