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Legal Document

AML/KYC Policy

v1.0.0-draftEffective: 2026-06-01Last updated: 2026-06-01

This is a working draft. The final text must be reviewed by legal counsel before commercial launch.

Quick Summary

TalixTrade is trading-bot software, not an exchange, bank, or custodian — we never hold your funds, accept deposits, or convert fiat. We do basic checks (email verification and sanctions screening) and monitor for clearly abusive patterns, but full identity verification (KYC) happens on your own exchange. You must use the service only with legitimate funds and must not be on any sanctions list.

Our AML Commitment

TalixTrade is operated by Anton Shchur, an Individual Entrepreneur (FOP) registered in Ukraine (2011600000000040678), at Dnipro, Dnipropetrovsk Oblast, Ukraine.

We take anti-money-laundering (AML) and counter-terrorism-financing seriously, and we want to be honest about what that means for a product like ours. TalixTrade is software — a bot builder, Smart Trade, signals, backtesting, paper mode, AI tools (Builder, Risk Manager, Optimizer, Assistant) and Auto-Hedge. We are not an exchange, bank, broker, custodian, or financial advisor.

Because of that, our role in the AML chain is limited but real. We describe below exactly what we do, what we do not do, and what we expect from you.

This is a draft policy prepared for later review by qualified counsel. It is not a substitute for legal advice.

What We Do

Within the scope of a software platform that never touches your money, we take the following measures:

  • Email verification. Every account is tied to a verified email address so that we can identify the account holder for our own records and communications.
  • Sanctions screening. We screen users against applicable sanctions and watchlists, including OFAC, EU, and UN lists, and we block service to sanctioned persons and restricted regions.
  • Monitoring for suspicious patterns. Our systems look for clearly abusive or manipulative trading behavior, such as wash trading or other patterns that have no legitimate economic purpose. Where we detect such activity, we may pause, restrict, or close the account.
  • Record keeping. We keep reasonable records of account information, sanctions checks, payments, and relevant activity for as long as needed to meet our obligations and to respond to lawful requests.
  • Reporting suspicious activity. Where we are legally required to report suspicious activity to a competent authority, we will do so, and we may be prohibited by law from telling you that we have done so.

What We Do NOT Do

It is important to be clear about the limits of our role:

  • We do not perform full KYC. We do not collect government IDs, proof of address, or other full identity documentation. Full "Know Your Customer" verification is done by your exchange (Binance, Bybit, OKX) when you open and fund your trading account there. That is where the regulated onboarding happens.
  • We do not hold your funds. Your money stays on your own exchange account at all times. We never accept deposits, never withdraw from your exchange account, and never act as a custodian. We connect only through an exchange API key with withdrawal permission disabled.
  • We do not convert fiat. We are not a money-services business or currency exchange. We do not exchange fiat for crypto or crypto for fiat. Our own paid plans are charged separately and described in our Terms of Service and Refund Policy.

User Obligations

By using TalixTrade, you confirm and agree that:

  • You will not use the service to launder money, finance terrorism, or facilitate any other crime.
  • The funds you trade with are legitimately yours and were obtained lawfully.
  • You are not subject to, or named on, any sanctions list (including OFAC, EU, or UN lists), and you are not acting on behalf of any sanctioned person.
  • You will not use the service from, or on behalf of anyone in, a fully restricted country or territory (see Sanctions Compliance below).
  • The information you give us (including your email) is accurate, and you will keep it up to date.

If any of these stops being true, you must stop using the service and contact us.

Sanctions Compliance

We do not provide the service to users in fully restricted countries or territories, in line with applicable sanctions (including OFAC). These currently include:

  • North Korea (KP)
  • Iran (IR)
  • Syria (SY)
  • Cuba (CU)
  • Occupied territories, including Crimea

We may add or update restricted regions at any time to stay compliant. If we determine that you are located in, or acting for someone in, a restricted region — or that you appear on a sanctions list — we may suspend or terminate your access without notice and may be required to report it.

Sanctions rules change. It is your responsibility to make sure that using the service is lawful where you are.

Suspicious Activity Indicators

The following are examples of activity that may trigger review, restriction, or reporting. This list is illustrative, not exhaustive:

  • Wash trading or other patterns of trades that appear designed to create artificial volume rather than to make a genuine market bet.
  • Trading behavior that looks structured to disguise the origin of funds.
  • Attempts to use the service from a restricted region, or to hide your true location (for example, repeated mismatches that suggest evasion).
  • Use of multiple accounts in a way that appears intended to circumvent limits, screening, or a prior suspension.
  • Connecting exchange accounts or making payments in a way that suggests third-party funds you are not entitled to use.
  • Any other behavior that has no apparent lawful or economic purpose.

Detecting an indicator does not mean we conclude wrongdoing; it means we may look more closely.

Cooperation with Authorities

We will cooperate with lawful requests from competent authorities. This includes responding to valid court orders, subpoenas, regulatory requests, and law-enforcement requests that we are legally obliged to honor.

When the law allows, and when doing so would not undermine an investigation, we aim to limit disclosure to what is legally required. In some cases the law may prohibit us from telling you that a request was made or that information was shared.

For more on how we handle your data generally, see our Privacy Policy.

Contact

Questions about this policy, or notices related to AML, sanctions, or suspicious activity, can be sent to our privacy contact at:

[email protected]

We will route your message to the right person internally.

Questions about this document: [email protected]