ClickOptions KYC/AML Policy

This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy (“Policy”) outlines the procedures ClickOptions operated by Gamma Desk S.A., registration number 155773887, incorporated in Panama (“Company”, “we”, “us”) follows to verify the identity of clients and to prevent money laundering, terrorist financing, fraud, and other financial crimes.

This Policy applies to all users of the ClickOptions platform and/or website (the “Platform and/or the Website”).

ClickOptions is committed to complying with applicable laws and international standards, including, without limitation:

• Financial Action Task Force (FATF) Recommendations,
• EU Anti-Money Laundering Directives (AMLD),
• U.S. Bank Secrecy Act (BSA) and FinCEN guidance,
• Dubai Virtual Asset Regulatory Authority (VARA) requirements, and
• Other applicable AML/CTF obligations in relevant jurisdictions.

3.1 Initial Onboarding

Requirements: Email or wallet registration and activation of Two-Factor Authentication (2FA).

Permissions:

• Crypto deposits permitted up to a limited threshold.
• Withdrawals locked until further verification is completed.

Purpose: Allows users to register and explore the Platform and/or the Website with minimal friction while preventing withdrawals until verification.

3.2 Standard Verification

Requirements:

• Government-issued photo ID,
• Live selfie verification,
• Proof of residential address (utility bill, bank statement, or government correspondence not older than 90 days).

Permissions:

• Full access to deposits, trading, and withdrawals up to defined limits.
• Eligibility to participate in the affiliate program.

Purpose: Ensures that the majority of clients are verified in accordance with global AML standards.

3.3 Institutional Verification

Requirements:

• Certificate of incorporation and Articles of Association,
• Register of directors and ultimate beneficial owners (UBOs),
• Board resolution authorizing account opening,
• Verification of directors and shareholders holding 25% or more,
• Proof of Source of Funds / Source of Wealth as required.

Permissions:

• Custom trading and withdrawal limits.
• Access to institutional account features and dedicated account management.

Certain users and transactions may be subject to additional checks, including but not limited to:

• Politically Exposed Persons (PEPs),
• Clients from high-risk jurisdictions,
• Large or unusual transactions,
• Activity inconsistent with the user's profile.

EDD measures may include requests for additional documents such as Source of Funds (SoF), Source of Wealth (SoW), and other supporting information.

ClickOptions implements ongoing monitoring of user activity on the Platform and/or the Website to detect suspicious or unusual behavior. This includes, without limitation:

Sanctions & Watchlist Screening

All clients and transactions are screened against international sanctions lists (OFAC, UN, EU, UK, and other relevant authorities).

On-Chain Transaction Screening (KYT)

Deposits and withdrawals are subject to blockchain analytics performed by third-party custodians (e.g., Bit-Go, Fireblocks, Copper, Cobo, ClearLoop).

Transactions involving high-risk, illicit, or sanctioned wallets may be blocked or frozen pending compliance review.

Automated Risk Monitoring

The Company uses automated monitoring tools to flag unusual trading activity, large or rapid transfers, and patterns inconsistent with a client's profile.

Affiliate & Commission Abuse Controls

The Company actively monitors for wash-trading, matched trading, circular trading, and self-dealing designed to generate artificial affiliate commissions or disguise the origin of funds.

Affiliate payouts may be withheld, adjusted, or clawed back where such activity is suspected, as further detailed in the Affiliate Terms & Conditions.

Suspicious Activity Reporting

Where suspicious or unlawful activity is identified, ClickOptions may freeze accounts, suspend transactions, and file suspicious activity reports (SARs/STRs) with the relevant competent authorities.

ClickOptions partners with regulated third-party providers to assist with compliance:

Identity Verification Providers: ClickOptions uses providers such as Veriff, SumSub, or equivalent to process client identity verification and securely store verification data.

Custodians & Transaction Screening: Client digital assets are held with independent third-party custodians, including but not limited to Fireblocks, Copper, Cobo, or ClearLoop. These custodians implement on-chain anti-money laundering (AML) and Know Your Transaction (KYT) screening tools to detect and block high-risk or sanctioned transactions at the wallet level.

By using the Platform and/or the Website, you consent to the collection, processing, and screening of your data and transactions by such providers. All personal data is handled in accordance with the Company's Privacy Policy.

All records of identity verification, account activity, and transaction history are retained for a minimum of five (5) years after account closure, in accordance with international AML obligations.

• Users are required to provide accurate and up-to-date information at all times.
• Users are responsible for ensuring that their use of the Platform and/or the Website is lawful in their jurisdiction.
• Attempting to misrepresent identity, jurisdiction, or funding source may result in account suspension, reporting to competent authorities, and loss of access to services.

ClickOptions reserves the right to deny access, suspend accounts, request additional documents, or terminate relationships where users fail to satisfy KYC/AML requirements or where suspicious activity is identified.