The purpose of ElevenTrust’s Anti-Money Laundering, Counter-Terrorist Financing, and Know Your Customer Policy (hereinafter referred to as the "AML/CTF and KYC Policy") is to identify, prevent, and mitigate the risks of ElevenTrust being involved in illegal activities.

To comply with international and local regulations, ElevenTrust has implemented robust internal procedures to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption, and bribery. We are committed to acting swiftly and responsibly in the event of any suspicious activity detected from our users.

AML refers to laws, regulations, and policies designed to prevent criminals from disguising illicitly obtained funds as legitimate assets. ElevenTrust ensures strict compliance with financial regulations to prevent fraudulent transactions.

CFT laws are designed to restrict access to financial services and funding for individuals and organizations involved in terrorism. By tracking the sources of funds that could support illicit activities, ElevenTrust ensures a secure financial environment and full compliance with relevant authorities.

Operating from Dubai, we strictly follow the guidelines set by the Central Bank of the UAE (CBUAE), the Securities and Commodities Authority (SCA), the Dubai Financial Services Authority (DFSA), and the Virtual Assets Regulatory Authority (VARA). Additionally, our policies are designed to meet Financial Action Task Force (FATF) recommendations, ensuring international compliance.

Compliance Structure & Risk Management

To maintain robust AML/CTF compliance, ElevenTrust has established a three-layered risk management model:

- The first line of defense consists of front-line employees responsible for customer due diligence (CDD) and risk identification.

- The second layer involves risk management and compliance teams that monitor transactions, investigate unusual patterns, and ensure strict adherence to AML protocols.

- The final layer includes internal audits to continuously assess the effectiveness of AML controls and prevent potential financial crime risks.

Know Your Client (KYC) & Customer Due Diligence (CDD)

Every client must complete a KYC verification before conducting any transactions on ElevenTrust. This process involves providing government-issued identification, proof of residence, and, for high-value transactions, additional financial documentation to verify the legitimacy of funds. We actively screen all customers against sanctions lists, politically exposed persons (PEP) databases, and high-risk country watchlists.

For higher-risk clients, Enhanced Due Diligence (EDD) is applied, requiring further scrutiny of source of funds, financial history, and business activities. Any client flagged for suspicious activity undergoes further compliance review, and if necessary, their transactions are reported to UAE financial regulators.

Transaction Monitoring & AML Controls

ElevenTrust enforces real-time monitoring of transactions to detect and prevent suspicious activities. Each trade is assessed using an automated risk-scoring system, which flags transactions that deviate from a client’s normal trading behavior. Transactions involving large sums, high-frequency activity, or potential structuring to avoid reporting thresholds are immediately reviewed.

If a transaction appears suspicious, we submit a Suspicious Activity Report (SAR) to UAE authorities. Additionally, any fiat-to-crypto or crypto-to-fiat transactions exceeding AED 55,000 ($15,000 equivalent) are documented through a Large Transaction Report (LTR) to ensure full regulatory transparency.

Risk-Based Approach & Compliance Reporting

Our risk management framework categorizes clients into low, medium, and high-risk profiles based on their trading history, transaction volume, and jurisdiction.

High-risk clients, particularly those from FATF-listed countries, are subject to deeper scrutiny to ensure full compliance with AML laws.

We work closely with UAE financial authorities to provide periodic AML audits, compliance reports, and regulatory filings. These efforts reinforce our commitment to maintaining a fully transparent and compliant financial ecosystem.

Regulatory Audits, Record-Keeping, and AML Training

All KYC and transaction records are securely stored for a minimum of five years, ensuring full traceability for regulatory audits. Our compliance team undergoes regular training to stay updated on evolving AML laws and best practices. Employees are trained to detect financial crime risks, handle compliance reports, and execute proper due diligence procedures.