Anti-Money Laundering (AML), Compliance & Acceptable Use

Effective 3 June 2026

1. Definitions and Interpretation

1.1 In this Acceptable Use Policy (this “Policy”), unless the context otherwise requires, the following terms shall have the meanings set out below:

(a) “Spondula”, “we”, “us”, and “our” means Spondula, the provider of the Services;
(b) “you”, “your”, and the “User” means any person who accesses or uses the Services;
(c) “Operators” means the independent operators, proprietary traders, liquidity providers, payment providers, and other independent ecosystem participants who provide services within, or in connection with, the ecosystem;
(d) “Services” means the Spondula ecosystem and the wallet infrastructure, identity verification services, S-Handles, and ecosystem technology made available by Spondula, together with any related services; and
(e) “Prohibited Activities” means the activities set out in clause 8 (Prohibited Activities).

1.2 The headings in this Policy are for convenience only and shall not affect its interpretation. References to “including” or “include” shall be construed as “including without limitation”, and any enumeration is illustrative and non-exhaustive.

2. Spondula’s Approach to Compliance

2.1 Spondula is committed to maintaining a secure, transparent, and compliant ecosystem.

2.2 To help protect Users and the wider network, Spondula operates risk-based compliance, fraud prevention, identity verification, sanctions screening, and monitoring procedures.

2.3 Our goal is to support legitimate activity while preventing misuse of the ecosystem.

2.4 This Policy supplements, and shall be read together with, our Terms of Use and our KYC & AML Policy information, and forms part of your agreement with Spondula.

3. Monitoring of Activity

3.1 Monitoring assists Spondula to:

(a) prevent fraud;
(b) detect suspicious activity;
(c) comply with legal obligations;
(d) protect Users;
(e) maintain ecosystem integrity;
(f) prevent abuse of rewards and promotions; and
(g) combat money laundering and financial crime.

3.2 For the avoidance of doubt, monitoring is automated and does not involve manual review of the content of your personal chat messages.

4. Sanctions Screening

4.1 Spondula may conduct sanctions screening and compliance checks where required by applicable laws, regulations, policies, and risk management procedures.

5. Requests for Additional Information

5.1 Spondula may, in certain circumstances, request additional information or documentation from you in order to satisfy compliance, fraud prevention, security, legal, or regulatory requirements.

5.2 Such information may include without limitation:

(a) proof of identity;
(b) proof of address;
(c) source of funds information;
(d) source of wealth information;
(e) business verification documents; and
(f) transaction explanations.

6. No Guarantee of Unrestricted Access

6.1 Completion of identity verification (KYC) does not guarantee unrestricted access to the Services. Identity verification is only one part of the compliance process.

6.2 Access to the Services may also depend on, including without limitation:

(a) jurisdiction;
(b) risk profile;
(c) transaction activity;
(d) sanctions screening;
(e) fraud prevention controls; and
(f) availability of independent ecosystem participants.

7. Refusal of Service

7.1 Spondula reserves the right to restrict access to certain Services where required by law, regulation, sanctions requirements, fraud prevention measures, security concerns, or violations of platform policies.

7.2 The Operators may apply their own compliance, onboarding, and risk management requirements, and may refuse or restrict service accordingly. Independent Operators, proprietary traders, liquidity providers, payment providers, and other ecosystem participants act independently in this regard.

8. Prohibited Activities

8.1 You shall not use, or attempt to use, the Services for, or in connection with, any activity that is unlawful, fraudulent, abusive, or otherwise prohibited, including without limitation any of the following:

(a) money laundering, layering, or disguising the origin of assets;
(b) terrorist financing or the proliferation of weapons;
(c) sanctions evasion, including transacting with, on behalf of, or for the benefit of any person or entity subject to sanctions by the UK (OFSI), EU, UN, or US (OFAC), or accessing the Services from a comprehensively sanctioned jurisdiction;
(d) identity theft or unauthorized use of another person’s identity, documents, or face;
(e) fraud, scams, or investment schemes (including romance fraud, fake giveaways, and Ponzi or pyramid schemes);
(f) transacting in stolen, counterfeit, or misrepresented assets, goods, or services;
(g) account takeovers;
(h) market manipulation, wash trading, or fabricated liquidity;
(i) referral abuse, reward farming, or manipulation of promotions;
(j) use of false, forged, tampered, stolen, or AI-generated documentation;
(k) operating multiple accounts to bypass KYC tier caps, transaction limits, or bans;
(l) structuring transactions (“smurfing”) to evade reporting thresholds or monitoring rules;
(m) circumventing compliance, security, or platform controls;
(n) phishing, spoofed login pages, or fraudulent messages impersonating Spondula, its staff, an Operator, a proprietary trader, a merchant, or another person or brand;
(o) chargeback or reversal fraud, including disputing a legitimate payment after value, tokens, or goods have been delivered;
(p) card-testing, BIN-farming, or bulk testing of stolen card numbers against gateway endpoints;
(q) recovery-scam services offering to “unlock” lost wallets, it being acknowledged that Spondula is non-custodial and that nobody can recover a lost recovery phrase;
(r) denial-of-service attacks, transaction flooding, or other attempts to overload the Spondula Chain or its supporting infrastructure;
(s) replaying, forging, or tampering with signed transactions, or exploiting software bugs in the Spondula Chain for gain;
(t) unauthorised scraping, reverse-engineering, decompiling, or extraction of keys, credentials, or private endpoints;
(u) spam, bulk unsolicited messaging, harassment, hate speech, threats, doxxing, or distribution of malware or scam links;
(v) registering S-Handles in bad faith, including squatting, resale for profit, or impersonation of a person, public figure, Operator, merchant, or brand;
(w) tax evasion or use of the Services to conceal taxable income; and
(x) bribery, kickbacks, or facilitation payments.

8.2 For the avoidance of doubt, this enumeration is non-exhaustive.

8.3 Buying tokens in order to sell immediately. You shall not buy S-Tokens (in particular using a credit or debit card) for the purpose, in whole or in part, of immediately or shortly thereafter selling or transferring out the equivalent value. Spondula treats such activity as an attempt to obtain a cash advance, or otherwise to circumvent this Policy, applicable card-scheme rules, and our compliance controls, and it constitutes a Prohibited Activity. Spondula and participating ecosystem providers may decline, delay, reverse, or restrict any such transaction and the associated account, and may require additional information before processing further activity.

9. Consequences of Suspicious Activity

9.1 Depending on the circumstances, Spondula or participating ecosystem providers may, including without limitation:

(a) request additional information;
(b) conduct enhanced due diligence;
(c) restrict access to certain Services;
(d) suspend participation in promotions;
(e) report activity where legally required; and
(f) terminate access to ecosystem services.

10. No Guarantee of Access to Liquidity, Operators, or Proprietary Traders

10.1 Spondula does not guarantee access to liquidity, Operators, or proprietary traders. Participation by independent ecosystem providers is subject to their own onboarding, compliance, risk management, and business requirements.

11. Wallet Freezes and Restriction of Access

11.1 Spondula operates a non-custodial wallet model and cannot directly seize, confiscate, or take control of assets held within a User’s wallet.

11.2 However, access to ecosystem services, liquidity providers, Operators, payment providers, and proprietary traders may be restricted where required by law, regulation, sanctions requirements, fraud prevention measures, or platform policies.

12. Reporting of Suspicious Activity

12.1 Where required by law, regulation, court order, legal process, or competent authority request, Spondula may cooperate with relevant authorities and provide information as legally required.

12.2 If you become aware of a breach of this Policy, including scams, fraudulent Operators, impersonation, or abusive handles, you should report it to [email protected]. You should include wallet addresses, handles, transaction hashes, and screenshots where possible. Spondula will not retaliate against Users who report in good faith.

13. No Legal, Tax, Financial, or Investment Advice

13.1 Spondula does not provide legal, tax, financial, or investment advice. Spondula provides wallet infrastructure, identity verification services, S-Handles, and ecosystem technology. Users should seek independent professional advice where appropriate.

Anti-Money Laundering (AML), Compliance & Acceptable Use

Effective 3 June 2026

1. Definitions and Interpretation

1.1 In this Acceptable Use Policy (this “Policy”), unless the context otherwise requires, the following terms shall have the meanings set out below:

(a) “Spondula”, “we”, “us”, and “our” means Spondula, the provider of the Services;
(b) “you”, “your”, and the “User” means any person who accesses or uses the Services;
(c) “Operators” means the independent operators, proprietary traders, liquidity providers, payment providers, and other independent ecosystem participants who provide services within, or in connection with, the ecosystem;
(d) “Services” means the Spondula ecosystem and the wallet infrastructure, identity verification services, S-Handles, and ecosystem technology made available by Spondula, together with any related services; and
(e) “Prohibited Activities” means the activities set out in clause 8 (Prohibited Activities).

2. Spondula’s Approach to Compliance

2.1 Spondula is committed to maintaining a secure, transparent, and compliant ecosystem.

2.2 To help protect Users and the wider network, Spondula operates risk-based compliance, fraud prevention, identity verification, sanctions screening, and monitoring procedures.

2.3 Our goal is to support legitimate activity while preventing misuse of the ecosystem.

2.4 This Policy supplements, and shall be read together with, our Terms of Use and our KYC & AML Policy information, and forms part of your agreement with Spondula.

3. Monitoring of Activity

3.1 Monitoring assists Spondula to:

(a) prevent fraud;
(b) detect suspicious activity;
(c) comply with legal obligations;
(d) protect Users;
(e) maintain ecosystem integrity;
(f) prevent abuse of rewards and promotions; and
(g) combat money laundering and financial crime.

3.2 For the avoidance of doubt, monitoring is automated and does not involve manual review of the content of your personal chat messages.

4. Sanctions Screening

4.1 Spondula may conduct sanctions screening and compliance checks where required by applicable laws, regulations, policies, and risk management procedures.

5. Requests for Additional Information

5.1 Spondula may, in certain circumstances, request additional information or documentation from you in order to satisfy compliance, fraud prevention, security, legal, or regulatory requirements.

5.2 Such information may include without limitation:

(a) proof of identity;
(b) proof of address;
(c) source of funds information;
(d) source of wealth information;
(e) business verification documents; and
(f) transaction explanations.

6. No Guarantee of Unrestricted Access

6.1 Completion of identity verification (KYC) does not guarantee unrestricted access to the Services. Identity verification is only one part of the compliance process.

6.2 Access to the Services may also depend on, including without limitation:

(a) jurisdiction;
(b) risk profile;
(c) transaction activity;
(d) sanctions screening;
(e) fraud prevention controls; and
(f) availability of independent ecosystem participants.

7. Refusal of Service

8. Prohibited Activities

(a) money laundering, layering, or disguising the origin of assets;
(b) terrorist financing or the proliferation of weapons;
(c) sanctions evasion, including transacting with, on behalf of, or for the benefit of any person or entity subject to sanctions by the UK (OFSI), EU, UN, or US (OFAC), or accessing the Services from a comprehensively sanctioned jurisdiction;
(d) identity theft or unauthorized use of another person’s identity, documents, or face;
(e) fraud, scams, or investment schemes (including romance fraud, fake giveaways, and Ponzi or pyramid schemes);
(f) transacting in stolen, counterfeit, or misrepresented assets, goods, or services;
(g) account takeovers;
(h) market manipulation, wash trading, or fabricated liquidity;
(i) referral abuse, reward farming, or manipulation of promotions;
(j) use of false, forged, tampered, stolen, or AI-generated documentation;
(k) operating multiple accounts to bypass KYC tier caps, transaction limits, or bans;
(l) structuring transactions (“smurfing”) to evade reporting thresholds or monitoring rules;
(m) circumventing compliance, security, or platform controls;
(n) phishing, spoofed login pages, or fraudulent messages impersonating Spondula, its staff, an Operator, a proprietary trader, a merchant, or another person or brand;
(o) chargeback or reversal fraud, including disputing a legitimate payment after value, tokens, or goods have been delivered;
(p) card-testing, BIN-farming, or bulk testing of stolen card numbers against gateway endpoints;
(q) recovery-scam services offering to “unlock” lost wallets, it being acknowledged that Spondula is non-custodial and that nobody can recover a lost recovery phrase;
(r) denial-of-service attacks, transaction flooding, or other attempts to overload the Spondula Chain or its supporting infrastructure;
(s) replaying, forging, or tampering with signed transactions, or exploiting software bugs in the Spondula Chain for gain;
(t) unauthorised scraping, reverse-engineering, decompiling, or extraction of keys, credentials, or private endpoints;
(u) spam, bulk unsolicited messaging, harassment, hate speech, threats, doxxing, or distribution of malware or scam links;
(v) registering S-Handles in bad faith, including squatting, resale for profit, or impersonation of a person, public figure, Operator, merchant, or brand;
(w) tax evasion or use of the Services to conceal taxable income; and
(x) bribery, kickbacks, or facilitation payments.

8.2 For the avoidance of doubt, this enumeration is non-exhaustive.

9. Consequences of Suspicious Activity

9.1 Depending on the circumstances, Spondula or participating ecosystem providers may, including without limitation:

(a) request additional information;
(b) conduct enhanced due diligence;
(c) restrict access to certain Services;
(d) suspend participation in promotions;
(e) report activity where legally required; and
(f) terminate access to ecosystem services.

10. No Guarantee of Access to Liquidity, Operators, or Proprietary Traders

11. Wallet Freezes and Restriction of Access

11.1 Spondula operates a non-custodial wallet model and cannot directly seize, confiscate, or take control of assets held within a User’s wallet.

12. Reporting of Suspicious Activity

12.1 Where required by law, regulation, court order, legal process, or competent authority request, Spondula may cooperate with relevant authorities and provide information as legally required.

The fine print.

Anti-Money Laundering (AML), Compliance & Acceptable Use

1. Definitions and Interpretation

2. Spondula’s Approach to Compliance

3. Monitoring of Activity

4. Sanctions Screening

5. Requests for Additional Information

6. No Guarantee of Unrestricted Access

7. Refusal of Service

8. Prohibited Activities

9. Consequences of Suspicious Activity

10. No Guarantee of Access to Liquidity, Operators, or Proprietary Traders

11. Wallet Freezes and Restriction of Access

12. Reporting of Suspicious Activity

13. No Legal, Tax, Financial, or Investment Advice

The fine print.

Anti-Money Laundering (AML), Compliance & Acceptable Use

1. Definitions and Interpretation

2. Spondula’s Approach to Compliance

3. Monitoring of Activity

4. Sanctions Screening

5. Requests for Additional Information

6. No Guarantee of Unrestricted Access

7. Refusal of Service

8. Prohibited Activities

9. Consequences of Suspicious Activity

10. No Guarantee of Access to Liquidity, Operators, or Proprietary Traders

11. Wallet Freezes and Restriction of Access

12. Reporting of Suspicious Activity

13. No Legal, Tax, Financial, or Investment Advice