Legal

AML Policy

Last updated: March 1, 2026 · Nextoken Capital UAB · FATF Aligned · Lithuania Registered

Section 1
Our Commitment

Nextoken Capital UAB is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. We are subject to the EU AML Directives (AMLD4, AMLD5, AMLD6), the Lithuanian Law on the Prevention of Money Laundering and Terrorist Financing, and FATF recommendations for virtual asset service providers.

Section 2
Know Your Customer (KYC)

All users must complete identity verification before investing or issuing assets on the platform. We verify: full legal name; date of birth; nationality and country of residence; government-issued photo ID (passport, national ID, or driver's license); and proof of address for higher-risk profiles. KYC is powered by Sumsub, a regulated identity verification provider.

Section 3
Risk-Based Approach

We apply a risk-based approach to customer due diligence. Standard due diligence applies to most customers. Enhanced due diligence is applied to: politically exposed persons (PEPs); customers from high-risk jurisdictions as identified by FATF; customers with complex ownership structures; and transactions above defined thresholds.

Section 4
Transaction Monitoring

We continuously monitor transactions on the platform for suspicious activity. Our monitoring systems flag: unusual transaction patterns; transactions inconsistent with a customer's profile; transactions involving high-risk jurisdictions; and rapid movement of funds without apparent economic purpose. Flagged transactions are reviewed by our compliance team.

Section 5
Suspicious Activity Reporting

When we identify suspicious activity, we are required by law to file a Suspicious Activity Report (SAR) with the Financial Crime Investigation Service (FNTT) of Lithuania. We are prohibited by law from informing the customer that a report has been made. We cooperate fully with law enforcement agencies upon receipt of a valid legal request.

Section 6
Prohibited Jurisdictions

We do not provide services to residents or entities from jurisdictions subject to comprehensive EU or UN sanctions, including but not limited to: North Korea, Iran, Russia (for certain services), Belarus, and other jurisdictions on the FATF blacklist or EU high-risk third country list. This list is updated regularly in line with regulatory changes.

Section 7
Source of Funds

For investments above certain thresholds, we may request evidence of the source of funds, including: employment income documentation; business ownership or income records; inheritance or gift documentation; or proceeds from asset sales. We reserve the right to refuse transactions where the source of funds cannot be satisfactorily verified.

Section 8
Record Keeping

We retain KYC and AML records for a minimum of 5 years after the end of the business relationship, in compliance with EU AML Directives. Records are stored securely and accessed only by registered compliance personnel.

Section 9
Training and Governance

Our AML Compliance Officer oversees all AML/CTF activities and reports directly to senior management. All staff receive regular AML training. Our AML programme is reviewed annually and updated to reflect regulatory changes and emerging risks.

Section 10
Contact

To report suspicious activity or for AML compliance enquiries, contact our Compliance Officer at compliance@nextokencapital.com. For urgent matters, you may also contact us by post at: Nextoken Capital UAB, Gynėjų g. 14, Vilnius 01109, Lithuania.