2 User admission and AML CFT 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's proposed services are private and invitation-only for approved professional clients. Admission requires an assessment of identity, ownership/control, authority, countries, expected activity, funding and asset provenance. AYOV may request certified or independently verifiable records, ownership charts, mandate evidence and information about counterparties. Documents must be supplied through the agreed secure channel, not a public blockchain or an unverified message thread.

Higher-risk relationships, politically exposed persons, complex structures and unexplained transactions require enhanced review. An invitation, existing business relationship, allocation letter or wallet balance does not replace checks. An application may be refused where mandatory information is missing or unacceptable. No public material guarantees approval.

Activity may be monitored against the declared purpose and profile. Wallets and relevant parties may be screened, and additional originator/beneficiary information may be required for virtual-asset transfers. AYOV may lawfully share information with competent authorities and regulated providers. Restrictions on disclosure may prevent explanations of a particular review or report. AYOV does not require clients to disclose private keys or seed phrases.

AML, sanctions and fraud controls are separate from investment suitability and reserve verification. Passing one check does not certify the others. Compliance questions should be directed to compliance@ayovcapital.com. Clients should not send transactions to “test” or bypass eligibility restrictions without accepted instructions.