AML/KYC Policy

NeuPortal · Beta testing edition of 03.11.2026 · Contact: [email protected]

Section 1. KYC/AML procedures through the Didit infrastructure

1.1. To counter the laundering of criminal proceeds and to protect the Platform's internal hot/cold wallets from "dirty" digital assets, the NeuPortal project has integrated the compliance solutions of the independent provider Didit and also uses its own controls (including automatic checking of wallet addresses against the OFAC sanctioned-address list, updated daily).

1.2. Verification (KYC) is not mandatory in the basic scenario. A User can register, deposit and place assets in AI-terminal plans without providing documents. Without verification, the withdrawal limits shown in the account apply (per 24 hours and per 30 days); by completing verification through the built-in Didit interface, the User raises or removes these limits.

1.3. The Administration may require KYC, additional information or documents (including on the source of funds) at any time — on risk signals, large or unusual operations, list matches or signs of a breach of the Terms & Conditions. Until they are provided, certain operations may be suspended.

1.4. Only persons aged 18 or over can be verified. Verification may be refused to persons from restricted jurisdictions and persons matching sanctions lists.

Section 2. Screening of wallets and transactions (AML)

2.1. The Platform may screen, through Didit and its own tools, the addresses from which deposits arrive and the addresses to which withdrawals are requested. The scope of screening (all operations, operations above threshold amounts, aggregate amounts over a period, or on a sample basis) is set by the Administration, which may change it — including enabling screening of all operations — without amending this Policy.

2.2. Previously screened addresses may be re-screened periodically. Screening results (risk score, sanctions flags, risk categories) are kept as part of the AML records.

Section 3. Rights of the Administration and risk monitoring

3.1. The Platform Administration relies on the results of the automatic AML scoring of blockchain transactions provided by Didit and on the results of its own checks. The procedures are carried out under the Platform's internal security regulations; where a result is disputed, the final decision is taken by an authorised Platform employee.

3.2. The Administration has the right to unilaterally and temporarily freeze the internal balance of digital assets, hold a deposit until screening is complete, refuse a deposit/withdrawal or internal transfer, or restrict access to the AI terminals for any user whose wallet or transaction has been rated high risk by the Didit infrastructure or the Platform's systems, until the user provides the necessary clarification to the Platform's support at [email protected]. These measures are taken solely to prevent the technical beta test from being used for unlawful purposes.

3.3. A withdrawal to an address on a sanctions list is not executed. In case of a sanctions match, restrictions remain until the Administration decides and may be indefinite; funds may be held or returned in the manner permitted by applicable law.

3.4. Large withdrawals may be sent for manual review by an employee before execution.

3.5. Where the law prohibits informing the User of the reasons for a measure (for example, a report to a competent authority), the Administration may withhold those reasons.

Section 4. User obligations

The User undertakes to: use only their own funds of lawful origin; not pass third-party funds through the Platform; not split operations to avoid checks and limits; not use the Platform to evade sanctions; provide accurate information and documents on request.

Section 5. Record keeping and data protection

Records of verification, address screening and operations are kept for 5 years after the account is closed or another period required by applicable law. Data is processed under the Privacy Policy; the copy of the provider's decision is stored encrypted, with every access logged.

Section 6. Restricted jurisdictions

The Platform is not available to persons who reside or are located in the following jurisdictions: the Democratic People's Republic of Korea (North Korea), Iran, Cuba, Syria, Crimea and the areas of the Donetsk and Luhansk regions not controlled by Ukraine, and the United States of America (for the beta-testing period). Persons from these jurisdictions and persons on sanctions lists are not admitted to the Platform.

Section 7. Changes, severability, contact

The Administration may change this Policy, including widening the scope of checks; the current version is published on the site. The invalidity of any provision does not affect the others. Nothing in this Policy limits any rights of the User that cannot be limited under applicable law. Questions and clarifications about checks: [email protected].