⚖️AML Policy

Introduction: Ape Church, operated by ZeroXSum Inc., a British Virgin Islands company, is committed to providing a secure platform for all users. The platform includes built-in blacklisting capabilities for cryptocurrency wallets and users suspected of engaging in malicious or unethical activities, including money laundering and terrorist financing.

This Anti-Money Laundering (AML) Policy outlines our risk-based approach aligned with applicable AML and sanctions standards (e.g., FATF). We screen wallet activity and may request additional information if necessary to cooperate with law enforcement and regulatory bodies.

Objective of the AML Policy: We are dedicated to preventing the use of our platform for illicit financial activities. To this end, we monitor wallet activities and engage in risk management processes, including potential blacklisting of wallets involved in unethical practices, including but not limited to money laundering.

Definition of Money Laundering: Money laundering refers to actions that involve the conversion, transfer, concealment, or disguise of illegally obtained property, typically to hide its criminal origins or evade legal consequences. This includes:

• Converting or transferring property derived from criminal activity to conceal or disguise its illegal origin.

• Participating in activities that facilitate the commission of illegal acts.

• Possessing or using property known to be derived from illegal activities.

Money laundering is considered an offense even when the activities generating the illicit property took place in another jurisdiction.

Company Responsibility: The ZeroXSum Inc., is responsible for enforcing and supporting the prevention of money laundering as part of our AML efforts. Any significant changes to the AML policy will require approval from the managing director.

Know Your Customer (KYC) and Customer Due Diligence (CDD): Our platform utilizes a risk-based approach to Customer Due Diligence (CDD) to understand the nature and purpose of each user's relationship with us. This helps to build a user risk profile and identify any suspicious activity. This includes:

• Screening and monitoring cryptocurrency wallet risk profiles.

• Maintaining records of wallet activity.

• Verifying wallet associations with known terrorist groups or criminal entities.

We may employ third-party services, such as blockchain analysts or investigators, to assist in identifying suspicious activities and users. Where necessary, we may request additional information from users to clarify wallet ownership or resolve identified risks.

Acceptance Policy: We will not accept or will block users who:

• Are from restricted or prohibited jurisdictions. Not available in restricted regions, including but not limited to: Afghanistan, Australia, Austria, Belgium, Canada (Ontario, Québec), Central African Republic, China (including Hong Kong & Macao), Cuba, Czech Republic, Denmark, Democratic Republic of the Congo, France, Germany (state-based restrictions), Greece, Iran, Iraq, Italy, Libya, Lithuania, Myanmar (Burma), Netherlands, North Korea, Norway, Poland, Portugal, Romania, Russia (including Crimea, Donetsk & Luhansk regions of Ukraine), Singapore, Somalia, South Korea, South Sudan, Spain, Sudan, Sweden, Switzerland, Syria, Turkey, United Arab Emirates, United Kingdom, United States (including all territories: Guam, Puerto Rico, US Virgin Islands), Venezuela (certain government-linked entities), Yemen, Zimbabwe.

• Are listed on sanctions or watch lists, such as those maintained by the United States, European Union, or other global regulatory bodies.

• Are suspected of being involved in illegal activities.

We reserve the right to block or suspend users at our discretion to protect the integrity of the platform.

Transaction Monitoring: We regularly monitor user activity to detect and report unusual patterns, as required by AML regulations. This includes:

• Monitoring wallet transactions for unusual patterns such as large or frequent stakes.

• Identifying any discrepancies or patterns that might suggest illegal activity.

Screening for Sanctioned Parties: We conduct periodic screenings of user wallets against applicable sanctions databases, leveraging third-party blockchain forensics tools like Chain analysis. This screening helps to identify illicit activity and ensure compliance with global regulations.

Contact Us: If you have any questions about our AML policy, please feel free to contact us via email [email protected].

Last Updated: November 26, 2025