5 Sanctions and prohibited activity policy

Version 1.0 | 16 October 2026

These policies describe the proposed Vanuatu services of AYOV CAPITAL MANAGEMENT LTD. Licensing applications are being prepared; no licence grant is represented. The responsible provider must be identified in the accepted service agreement. Publishing these policies does not change the operator of an existing service.

AYOV prohibits unlawful sanctions evasion, money laundering, terrorism financing, proliferation financing, fraud, market abuse and use of stolen assets. Checks cover customers and relevant owners/controllers, counterparties, providers, banks and wallets. Applicable UN and Vanuatu measures and other regimes with a relevant nexus or contractual requirement must be assessed.

A possible match may delay an instruction while identifiers and ownership are checked. A confirmed restriction may require lawful blocking, freezing, rejection or reporting. Assets must not be returned or converted in breach of a restriction. AYOV cannot remove a legal restriction by commercial agreement, and staff may be unable to disclose confidential reporting details.

Clients must provide truthful information and may supply reliable evidence to correct an erroneous match through Compliance. A screening result is not a general accusation of wrongdoing. Decisions and releases require recorded review. Using a new wallet, intermediary or chain to circumvent a restriction is prohibited.