AML/CFT Policy

Vaulta Digital Assets Ltd (“Vaulta”) is committed to preventing money laundering, terrorist financing, proliferation financing, and sanctions evasion. Vaulta operates strictly as a business-to-business provider and does not offer retail, anonymous, or peer-to-peer services.

Vaulta applies a risk-based approach across customers, products, channels, jurisdictions, and transactions, aligned with the Anti-Money Laundering Act, 2020 (Act 1044), the Anti-Terrorism Act, 2012 (Act 842), the Virtual Asset Service Providers Act, 2026 (Act 1154), the Data Protection Act, 2012 (Act 843), and the FATF Recommendations.

The Board of Directors approves this policy and appoints a Money Laundering Reporting Officer (MLRO) with the independence and authority to oversee the programme, challenge business decisions, and report to competent authorities. Vaulta operates a three-lines-of-defence model separating business, compliance, and independent review.

Access is limited to eligible institutions. Vaulta verifies the identity of the entity, its beneficial owners, directors, and authorised users, and assesses the nature and purpose of the relationship before onboarding. No business relationship is established until due diligence is completed and approved.

Enhanced due diligence applies to higher-risk clients, politically exposed persons, and clients connected to higher-risk jurisdictions. Enhanced measures include additional verification, source-of-funds and source-of-wealth review, senior approval, and heightened monitoring.

Vaulta screens clients, beneficial owners, and counterparties against applicable sanctions lists, including United Nations, OFAC, European Union, United Kingdom, and Bank of Ghana lists, at onboarding and on an ongoing basis. Vaulta does not establish or maintain relationships involving sanctioned parties.

Vaulta monitors activity on a continuous and periodic basis against each client’s expected profile, using fiat transaction monitoring and blockchain analytics to identify unusual or suspicious behaviour.

Personnel escalate red flags to the MLRO, who determines whether a report is required and, where so, files with the Financial Intelligence Centre in line with legal obligations. Vaulta strictly prohibits tipping-off.

Vaulta retains due diligence, transaction, and reporting records in line with statutory requirements, with a secure and auditable trail available to regulators and partners on lawful request.

All relevant personnel complete AML/CFT training at onboarding and periodically thereafter, reflecting Vaulta’s risk profile and regulatory obligations.

Vaulta’s AML/CFT framework is subject to periodic independent review, with findings tracked to closure.

Personal data processed for compliance purposes is handled in accordance with the Data Protection Act, 2012 (Act 843), encrypted in transit and at rest, and treated as confidential.

This policy is governed by the laws of the Republic of Ghana. Disputes are resolved by arbitration seated in Accra, Ghana.

Approved by the Board of Directors of Vaulta Digital Assets Ltd.