Anti-Money Laundering (AML), CTF & Sanctions Compliance Framework

1.1 Digital Edge Wave Corporate Entity. This Anti-Money Laundering ("AML"), Counter-Terrorist Financing ("CTF"), and Sanctions Compliance Framework is enacted and maintained by DIGITAL EDGE WAVE LTD (trading as "AlbaTherium", "the Company", or "we"), a private limited company registered in England and Wales under Company Registration Number 15074564, with registered office located at 483 Green Lanes, London, United Kingdom, N13 4BS.

1.2 Standard Industrial Classification (SIC). The Company operates under United Kingdom Standard Industrial Classification of Economic Activities (SIC): 62012 (Business and domestic software development), 62090 (Other information technology and computer service activities), 63990 (Other information service activities n.e.c.), and 47990 (Other retail sale not in stores, stalls or markets).

2.1 Statutory Regulatory Basis & Retail Ingestion. In accordance with the UK Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended 2019), FinCEN Customer Due Diligence (CDD) rules, and EU 5th/6th AML Directives, the Company implements risk-based verification prior to enabling terminal software access, institutional API keys, or retail dashboard credentials. Retail individual users and proprietary desks alike undergo automated identity verification and AML/OFAC sanctions screening upon sign-up and card onboarding via Stripe and Payabl:

2.2 Continuous Periodic Review. Client files are subject to automated monthly batch rescans against consolidated sanctions lists. Material changes in beneficial ownership trigger immediate re-attestation obligations.

3.1 Consolidated Directory Screening. DIGITAL EDGE WAVE LTD enforces automated, zero-tolerance screening against sanctions lists administered by the UK Office of Financial Sanctions Implementation (OFSI / UK HMT), the U.S. Office of Foreign Assets Control (OFAC SDN & SSI), the European Union Consolidated Financial Sanctions List, and United Nations Security Council (UNSC) resolutions.

3.2 Screening Integrations. Screening heuristics incorporate daily feeds from Dow Jones Risk & Compliance and Refinitiv World-Check to ensure zero onboarding of Specially Designated Nationals.

4.1 FATF Blacklist & Greylist Classifications. The Company maintains an active territorial exclusion schedule. AlbaTherium software licenses and cloud endpoints are categorically prohibited from deployment in jurisdictions classified as High-Risk Jurisdictions subject to a Call for Action:

4.2 Geographic Warranty. Subscribers and users (whether corporate desk operators or individual retail traders) represent and warrant that neither they nor any operating users are physically present in or citizens of prohibited jurisdictions.

5.1 FCM Margin Isolation & Retail Protection. AlbaTherium maintains zero possession or custody over user trading capital. Margin calculation, order clearing, derivative liquidation, and funds settlement occur exclusively at the client's authorized clearing broker or Futures Commission Merchant (FCM). This non-custodial architecture and complete margin isolation protects institutional desks, proprietary trading firms, and individual retail traders alike with zero client custody and zero commingling.

5.2 No Commingling. Under no circumstances does DIGITAL EDGE WAVE LTD hold, escrow, pool, or convert client margins, tokens, or collateral.

6.1 PCI-DSS Zero-Storage Tokenization. Software subscription payments, enterprise licensing, individual retail licenses, and data tier upgrades are processed through tier-1 PCI-DSS Level 1 compliant payment gateways: Stripe Technology Europe Ltd and Payabl (payabl.cy ltd / payabl.de GmbH), ensuring robust tokenization for both enterprise accounts and personal retail payment cards.

6.2 Refund, Retail Guarantee & Anti-Fraud Telemetry. Machine-learning fraud filters inspect transaction telemetry (IP geolocation consistency, issuing bank country match, address verification) without storing raw banking numbers on Company disks. Subscriptions for personal retail accounts include a statutory 14-day money-back guarantee under UK/EU Consumer Contracts Regulations with full cardholder dispute protections.

7.1 Authorized Conduits & Exchange Reporting. Market data pipelines, L2/L3 order book data, and live futures streaming are provided through authorized routing conduits: Rithmic LLC and Databento Inc. Non-Professional subscriber self-certification is strictly verified and monitored against exchange compliance rules (CME Group, ICE, Eurex, Nasdaq) to prevent unauthorized professional exploitation of discounted retail feeds.

• Subscriber Classification: Users must accurately declare their status as Non-Professional or Professional market data subscribers in compliance with CME Group, ICE, Eurex, and Nasdaq exchange bylaws.
• Audit Liability: Misrepresenting professional status constitutes a material breach and subjects the subscriber to retroactive exchange data billing and audit penalties.
• Key Isolation (BYOK): Rithmic connection credentials and Databento API keys are encrypted at rest with hardware AES-256-GCM in volatile RAM and never shared across tenant accounts.

7.2 No Cloud Caching. AlbaTherium processes exchange market data streams strictly within client-side sandboxes, avoiding centralized cloud storage or unlicensed re-syndication.

8.1 Deterministic AI Supervisions & Parity. AlbaTherium integrates the Candela AI Trading Assistant and Model Context Protocol (MCP) server endpoints. AI agentic tool calling is governed by strict deterministic compliance controls and risk perimeters (daily max loss limits, explicit trade confirmations, and parameter validation) that protect retail and institutional traders equally:

8.2 Zero Model Training. User prompt telemetry, quantitative heuristics, and proprietary order parameters are never utilized to train public foundation models.

9.1 Abuse Detection Heuristics. In alignment with UK Market Abuse Regulation (UK MAR), CFTC anti-disruptive practice rules, and the UK National Crime Agency (NCA) directives, the platform strictly prohibits spoofing, wash trading, quote stuffing, layering, and latency arbitrage abuse.

9.2 SAR Escalation Protocols. Suspicious transaction reports (SARs) are confidentially escalated to the NCA / FinCEN without customer tipping-off. Algorithmic patterns flagged for malicious market disruption result in instant terminal token revocation.

10.1 Statutory 7-Year WORM Storage. Pursuant to SEC Rule 17a-4 and CFTC 1.31, operational logs, connection IP timestamps, and telemetry records are committed to write-once-read-many (WORM) storage for 7 years to facilitate regulatory review.

10.2 Whistleblower & CCO Channel. Confidential reports of suspected sanctions evasion, illegal trading syndicates, or compliance breaches should be routed directly to the Chief Compliance Officer at: support@albatherium.com [Subject: Legal and Compliance].