Anti-Money Laundering & Counter-Terrorism Financing Policy

1. Introduction

Aquila Global Limited (“MyShrine”, Company No. 17407113) is committed to preventing money laundering, terrorist financing, and other financial crime in accordance with the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended), the Proceeds of Crime Act 2002, and the Terrorism Act 2000.

This policy applies to all transactions processed through the MyShrine platform, including tributes, product purchases, session bookings, custom requests, tips, and wallet top-ups.

2. Know Your Customer (KYC)

We carry out identity verification through our KYC provider, Didit, for all creators before they can receive payments. This includes:

• Government-issued photo ID verification (passport, driving licence, or national ID card)
• Biometric liveness check to confirm the person presenting ID is the ID holder
• Age verification (all users must be 18 or older)
• Ongoing monitoring — creators must re-verify if identity details change

Fan accounts require age verification. Enhanced due diligence may be applied to high-value or high-frequency transaction accounts.

3. Transaction Monitoring

We monitor transactions for suspicious patterns, including but not limited to:

• Unusually large or frequent transactions inconsistent with a user's normal activity
• Rapid movement of funds through the platform (layering)
• Transactions with no apparent economic or lawful purpose
• Unusual patterns of wallet top-ups and immediate withdrawals
• Multiple accounts linked to the same payment source or identity
• Transactions involving jurisdictions subject to international sanctions

4. Sanctions Screening

We block access from sanctioned and restricted jurisdictions (by IP location and by the country of each creator's identity document), verify every creator's identity with Didit, and check verified creator identities against the following sanctions lists before payouts are made:

• HM Treasury Consolidated List of Financial Sanctions Targets (UK)
• OFAC Specially Designated Nationals List (USA)
• EU Consolidated Financial Sanctions List
• UN Security Council Consolidated List

Accounts and transactions involving sanctioned individuals, entities, or jurisdictions are blocked, and reported to the relevant authorities where required.

5. Suspicious Activity Reporting

Where we identify or suspect money laundering, terrorist financing, or other financial crime, we will:

• File a Suspicious Activity Report (SAR) with the National Crime Agency (NCA) via the SAR Online system
• Suspend the affected account and freeze funds pending investigation
• Not tip off the account holder about the SAR filing (Tipping Off offence, POCA 2002 s.333A)
• Retain all relevant records for at least 5 years from the date of the report
• Cooperate fully with law enforcement and regulatory authorities

6. Record Keeping

In accordance with the Money Laundering Regulations 2017 (Regulation 40), we retain:

• Customer identification and verification records — 5 years after the business relationship ends
• Transaction records — 5 years from the date of the transaction (or 7 years where required for tax compliance)
• Suspicious activity reports and supporting evidence — 5 years from the date of the report

7. Staff Training & Awareness

All staff with access to transaction data or customer information receive training on:

• Recognising and reporting suspicious activity
• The legal obligations under the Proceeds of Crime Act 2002 and the Terrorism Act 2000
• The Tipping Off offence and confidentiality requirements
• Platform-specific red flags and escalation procedures

8. Nominated Officer

Aquila Global Limited has appointed a Nominated Officer (Money Laundering Reporting Officer) responsible for receiving and assessing internal suspicious activity reports, making SARs to the NCA where appropriate, and overseeing AML/CFT compliance.

The Nominated Officer can be contacted at compliance@myshrine.io.

9. Cryptocurrency-Specific Controls

As MyShrine processes cryptocurrency payments through NOWPayments, we apply additional controls specific to digital assets:

• Creator payout wallets are recorded and linked to verified identities
• Wallet address changes require re-verification and trigger admin review
• Fan wallet top-ups are linked to individual accounts for audit trail purposes
• All transactions are logged with timestamps, amounts, and associated user IDs

10. Reporting Concerns

If you suspect financial crime, money laundering, or terrorist financing on the platform, please contact us immediately:

• Email: compliance@myshrine.io
• Or report directly to the NCA: nationalcrimeagency.gov.uk

11. Policy Review

This policy is reviewed annually and updated as necessary to reflect changes in legislation, regulatory guidance, or our business operations. The most recent review was conducted in August 2026.