AML Policy

New Horizon Market is fully committed to preventing money laundering, terrorist financing, and other financial crimes on our platform. We take our legal and ethical responsibilities seriously and have implemented comprehensive procedures to detect, prevent, and report suspicious financial activity.

Our AML/CTF program is built on four pillars: robust customer due diligence (KYC), ongoing transaction monitoring, timely reporting of suspicious activity, and comprehensive record keeping. We continuously review and enhance our program to stay current with evolving regulatory requirements and emerging financial crime risks.

All employees, contractors, and platform users are expected to uphold these standards. Any attempt to use New Horizon Market for money laundering or terrorist financing will result in immediate account termination, fund freezing, and mandatory reporting to the relevant authorities.

We require all users to complete a thorough identity verification process before accessing full platform features. Our KYC process is designed to verify the identity of our customers and assess potential risks of illegal activity.

Our KYC process includes:

• Identity Verification: Government-issued photo ID (passport, national ID card, or driver's license).
• Proof of Address: Recent utility bill, bank statement, or official correspondence confirming residential address (typically less than 3 months old).
• Biometric Verification: Selfie or liveness check to confirm that the person submitting documents matches the identity documents provided.
• Enhanced Due Diligence: For high-risk customers or large transactions, we may require additional documentation such as source of funds evidence.

We use reputable third-party KYC and identity verification providers to assist with document verification and biometric checks. KYC verification must be completed before withdrawal limits are raised or access to certain products is granted.

We reserve the right to request additional information or documentation at any time, and to restrict or suspend accounts where KYC requirements are not met.

New Horizon Market continuously monitors transactions and account activity for patterns that may indicate money laundering, fraud, or other financial crimes. Our monitoring systems look for, but are not limited to, the following indicators:

When our monitoring systems or compliance team identify activity that may indicate money laundering, terrorist financing, or other financial crimes, we are legally obligated to file Suspicious Activity Reports (SARs) with the relevant financial intelligence units and regulatory authorities.

Due to legal requirements, we are prohibited from disclosing to any customer or third party that a suspicious activity report has been filed, or that an investigation is underway. This is known as the "tipping-off prohibition" and is a standard requirement under AML legislation globally. Violation of this prohibition is a serious criminal offence.

Accounts that are under investigation may be subject to restrictions on withdrawals, trading, or other activities without prior notice. We are unable to provide reasons for such restrictions in all cases due to legal constraints.

We maintain comprehensive records of all customer identification documents, verification outcomes, transactions, and compliance decisions. These records are retained in accordance with applicable legal requirements.

• Customer identification documents and KYC verification records: retained for a minimum of 7 years after the business relationship ends.
• Transaction records (deposits, withdrawals, trades): retained for a minimum of 7 years.
• Suspicious activity reports and supporting documentation: retained as required by local law, typically 5–7 years.
• AML risk assessments and compliance decisions: retained for the life of the customer relationship plus 7 years.

All records may be provided to law enforcement agencies, financial intelligence units, or regulatory authorities upon receipt of a valid legal request, court order, or subpoena. We cooperate fully with all lawful investigations.

New Horizon Market maintains a robust sanctions compliance program. We screen all customers and transactions against major international sanctions lists, including those maintained by:

• The United Nations Security Council (UNSC)
• The Office of Foreign Assets Control (OFAC) — USA
• The Financial Conduct Authority (FCA) — UK
• The European Union (EU) Consolidated Sanctions List
• Other relevant national and international bodies

Any account found to be associated with a sanctioned individual, entity, or jurisdiction will be blocked immediately. Funds may be frozen in accordance with applicable sanctions law, and the matter will be reported to the relevant authorities. We do not provide services to residents of comprehensively sanctioned countries including, but not limited to, those listed by OFAC.

Sanctions screening is performed at onboarding and on an ongoing basis. Our sanctions lists are updated regularly to reflect the latest designations.

All New Horizon Market team members who interact with customers, handle transactions, or have access to financial data receive comprehensive AML/CTF training. Our training program covers:

• The legal and regulatory framework for AML/CTF in all relevant jurisdictions.
• How to identify and escalate suspicious activity and red flags.
• Customer due diligence requirements and how to conduct enhanced due diligence.
• Sanctions compliance, including how to use screening tools and interpret results.
• Internal reporting procedures and the consequences of non-compliance.

Training is provided to all new staff before they begin work, and refresher training is conducted at least annually, or whenever there are material changes to relevant laws and regulations. Records of all AML training are maintained.

For AML-related inquiries, to report suspicious activity, or if you have concerns about potential financial crime on our platform, please contact our Compliance team directly:

We treat all compliance inquiries with strict confidentiality. Whistleblowers who report suspected financial crimes in good faith are protected from retaliation under applicable law.