Anti-Money Laundering Policy

1. Our Commitment

Heycube, trading as AjoCircle, is committed to preventing money laundering, terrorist financing, and other financial crime on our platform. We take our legal and ethical obligations in this area seriously.

We have implemented robust controls to identify, monitor, and report suspicious activity. All users of AjoCircle must comply with our AML controls as a condition of using the platform.

This policy applies to all users, to all transactions processed through AjoCircle, and to all third-party service providers acting on our behalf.

2. Legal Framework

Our AML controls are designed to comply with the following UK legislation and guidance:

• Proceeds of Crime Act 2002 (POCA) — criminalises money laundering and imposes obligations to report known or suspected money laundering to the National Crime Agency.
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) — requires customer due diligence, record keeping, and the implementation of AML policies and procedures.
• Terrorism Act 2000 — criminalises the provision of financial assistance to terrorists and requires reporting of known or suspected terrorist financing.
• Financial Sanctions legislation — we screen users against HM Treasury's UK financial sanctions list and do not permit sanctioned individuals to use the platform.

3. Customer Due Diligence

We apply customer due diligence (CDD) to all users as a condition of accessing the full functionality of AjoCircle. CDD includes:

Standard due diligence (all users)

• Phone number verification via one-time passcode
• Collection of full name, date of birth, and residential address
• Identity document verification via Stripe Identity (passport, driving licence, or national identity card)
• Biometric liveness check to confirm the document holder is present
• Sanctions screening against relevant UK and international lists

Enhanced due diligence

We apply enhanced due diligence in higher-risk situations, including:

• Circles where the total pot value exceeds a defined threshold
• Users whose transaction patterns are inconsistent with their stated profile
• Users who are politically exposed persons (PEPs) or associates of PEPs
• Users whose identity verification raises concerns or inconsistencies

Enhanced due diligence may involve requesting additional identity documents, source of funds information, or delaying access to the platform pending review.

4. What We Monitor

We actively monitor platform activity for indicators of money laundering or financial crime, including:

• Unusual contribution patterns — contributions significantly above or inconsistent with a user's stated financial profile.
• Multiple accounts — attempts by a single individual to operate more than one account, or to participate in circles under different identities.
• Circles with no genuine savings purpose — circles that appear designed to move money rather than facilitate genuine group savings (e.g. very short duration, unusually high amounts, immediate payout to the same person who created the circle).
• Structuring — breaking transactions into smaller amounts to avoid monitoring thresholds.
• Inconsistent identity information — discrepancies between the identity information provided at registration and information appearing in transaction records or communications.
• Rapid payout followed by withdrawal — receiving a payout and immediately withdrawing to an account with no apparent connection to the stated purpose.

Our audit log records all significant platform activity. We review flagged activity and apply a risk-based approach to determining whether further investigation or reporting is required.

5. Suspicious Activity Reporting

Where we know or suspect that a person is engaged in money laundering or terrorist financing, we are legally required under the Proceeds of Crime Act 2002 to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) via the SAR Online System.

Where consent is required before proceeding with a transaction, we will apply to the NCA for a Defence Against Money Laundering (DAML) before releasing any funds.

Suspension or restriction of your account during an investigation should not be taken as confirmation that a SAR has been made.

6. Record Keeping

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

• Customer due diligence records — including copies of identity verification results and supporting documentation — for 5 years from the end of the business relationship.
• Transaction records — records of all contributions and payouts — for 5 years from the date of the transaction.
• SAR records — records of any suspicious activity reports submitted to the NCA — for 5 years from the date of submission.

All records are stored securely and access is limited to authorised personnel. Records are available to law enforcement and regulatory authorities on request.

7. Operator Responsibilities

As the sole operator of AjoCircle, the platform operator (Heycube) is responsible for:

• Maintaining and regularly reviewing this AML Policy
• Ensuring all CDD procedures are followed for every user
• Monitoring platform activity for suspicious patterns
• Submitting SARs to the NCA where required
• Maintaining required records for the statutory retention period
• Cooperating with law enforcement and regulatory investigations
• Engaging competent legal and compliance advice where necessary

The operator will conduct a risk assessment of the platform at least annually and update AML controls in response to identified risks or changes in law or regulatory guidance.

8. Training & Awareness

The platform operator maintains awareness of:

• UK money laundering legislation and regulatory guidance
• Typologies and red flags associated with money laundering in peer-to-peer payment platforms
• Updates from the Financial Action Task Force (FATF) and HMRC guidance
• NCA guidance on submitting SARs

As the platform grows and additional staff are engaged, all personnel with AML responsibilities will be required to complete appropriate AML training on joining and at regular intervals thereafter.

9. Contact

If you have concerns about potential money laundering or financial crime on the AjoCircle platform, or if you wish to raise an AML-related matter, please contact us: