Anti-Money Laundering (AML) Policy

Last updated: 1 October 2026

1. Purpose & Scope

Ivy Connection PLC ("Ivy") is committed to preventing the use of its token sale platform for money laundering, terrorist financing, or any other illicit financial activity. This Anti-Money Laundering (AML) Policy applies to all participants in the seed, private, and public IVY token sale rounds, and describes the controls we apply before, during, and after any contribution.

2. Regulatory Commitment

While the IVY token is a utility token and the sale is structured to fall outside regulated financial services activity in the jurisdictions where it is offered, Ivy voluntarily applies AML and Know-Your-Customer (KYC) standards modelled on the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and guidance issued by the Financial Action Task Force (FATF) for virtual asset service providers. We review this Policy annually or upon material regulatory change.

3. Customer Due Diligence (KYC)

Before any individual may contribute to a token sale round, we require:

• Submission of a valid government-issued photo ID (passport, national ID card, or driving licence);
• A liveness check or selfie verification to confirm the ID belongs to the applicant;
• Proof of address dated within the last 3 months for contributions above $10,000 equivalent;
• Screening against global sanctions, politically exposed persons (PEP), and adverse media lists.

Verification is performed by a specialist third-party identity provider under contract; Ivy staff do not manually handle raw ID documents outside of escalated review cases.

4. Risk-Based Approach

We apply enhanced due diligence (EDD) to higher-risk participants, including those who are PEPs, contribute unusually large amounts relative to their verified profile, or are connected to jurisdictions identified by FATF as having strategic AML deficiencies. EDD may include source-of-funds documentation and senior management sign-off before a contribution is accepted.

5. Ongoing Monitoring

On-chain wallet addresses used to contribute to the sale are screened against known illicit-activity address lists (including sanctioned addresses and darknet market clusters) using blockchain analytics tooling. Contributions from flagged addresses are automatically held for manual review and may be refunded or rejected.

6. Sanctions Compliance

Ivy will not accept contributions from individuals or entities on sanctions lists maintained by the UK Office of Financial Sanctions Implementation (OFSI), the EU, the United Nations Security Council, or the US Office of Foreign Assets Control (OFAC), regardless of where the individual resides.

7. Reporting Obligations

Where our compliance team identifies activity reasonably suspected to relate to money laundering or terrorist financing, we will file a Suspicious Activity Report with the UK National Crime Agency or the equivalent authority in the relevant jurisdiction, and may freeze the associated account pending investigation, as required by law.

8. Prohibited Jurisdictions & Persons

In addition to sanctioned individuals, the following are categorically excluded from token sale participation:

• Residents and citizens of the United States and mainland China, where token sales of this nature are restricted or unregistered;
• Residents of any jurisdiction subject to comprehensive UK, EU, or UN sanctions (including but not limited to North Korea, Iran, Syria, and Crimea);
• Shell entities or structures that obscure beneficial ownership;
• Any applicant who fails or refuses to complete identity verification.

9. Record Keeping

Identity verification records, transaction records, and risk assessments are retained for a minimum of 5 years from the end of the business relationship, consistent with our Privacy Policy and applicable AML record-keeping requirements.

10. Training

All Ivy staff involved in token sale operations receive AML and sanctions-awareness training upon onboarding and annually thereafter. Our compliance team includes a designated Money Laundering Reporting Officer (MLRO) responsible for policy oversight and regulatory liaison.

11. Changes to This Policy

We may update this AML Policy to reflect changes in applicable law, regulatory guidance, or our risk assessment. Material changes affecting active sale-round participants will be communicated by email. The "Last updated" date above reflects the most recent revision.

12. Contact

Questions regarding this Policy or our compliance programme can be directed to our Money Laundering Reporting Officer:

Ivy Connection PLC
Ste 18, 100 Borough High Street, London, SE1 1LB
Email: compliance@ivymessenger.com