Anti-Money Laundering / Counter-Terrorist Financing Policy

1. Purpose

WITTY Technology Limited ("WITTY") is committed to preventing its platform from being used for money laundering, terrorist financing, or any other financial crime. This AML/CTF Policy outlines WITTY's risk-based approach to identifying, mitigating, and escalating potential AML/CTF risks.

2. Scope

This policy applies to all users of the WITTY platform, including:

• Exporters
• Importers
• Affiliates
• Partners and intermediaries

WITTY operates as a non-custodial growth and intelligence platform. All fund custody, settlement, and payment processing are handled by licensed financial partners who retain primary regulatory responsibility.

3. Risk-Based Approach

WITTY applies a risk-based AML/CTF framework that:

• Assesses customer risk at onboarding
• Continuously monitors behavioral and trade-related signals
• Applies enhanced scrutiny to higher-risk users

Risk factors considered include:

• Geographic location
• Industry sector
• Business model complexity
• Trade behavior patterns

4. AML Controls

WITTY implements the following AML controls:

• Identity and business verification (KYC/KYB)
• Platform-level behavioral monitoring
• AI-assisted anomaly detection
• Manual compliance review where necessary

5. Escalation & Cooperation

Where suspicious activity is detected:

• WITTY flags the activity internally
• Access may be restricted pending review
• Relevant information is escalated to the licensed payment partner for regulatory reporting

6. Record Keeping

WITTY maintains records of:

• Onboarding data
• Risk assessments
• Compliance reviews
• Escalations and actions taken

Contact Information

WITTY Technology Limited

Compliance & Support