AML / CFT DISCLAIMER

Last updated: June 2026

This Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Disclaimer explains the role of InstaXchange, a brand operated by NOOS sp. z o.o. ('InstaXchange', 'we', 'us'), in relation to anti-money laundering and counter-terrorist financing matters, and clarifies which entities are responsible for performing AML/CFT functions in connection with the Services.

InstaXchange's Role

InstaXchange operates a technology aggregation platform that enables Users to access independent, regulated crypto-asset service providers ('Licensed Providers') for fiat-to-crypto and crypto-to-fiat conversion transactions ('Conversion Transactions').

InstaXchange is not a party to any Conversion Transaction, does not execute or settle transactions, and does not hold or control any User funds or cryptoassets at any stage. As a consequence, InstaXchange is not an obliged entity under the EU Anti-Money Laundering Directive (Directive (EU) 2015/849, as amended), Regulation (EU) 2024/1624, or equivalent national AML/CFT legislation, and does not make any final AML/KYC decisions in respect of Users or transactions.

As part of its own risk management and merchant onboarding processes, InstaXchange may conduct preliminary, non-determinative screening of traffic, merchants, and Distribution Partners introduced to the Platform — including reviewing publicly available information, applying risk indicators, and monitoring for patterns of fraudulent, suspicious, or non-compliant activity. Such preliminary screening does not constitute customer due diligence under applicable AML/CFT legislation, does not substitute for the AML/CFT processes performed by Licensed Providers, and does not result in any determination as to a customer's identity, risk classification, or eligibility to transact. All such determinations are made exclusively by the relevant Licensed Provider.

Who Performs AML/CFT Functions

All AML/CFT functions in connection with a Conversion Transaction — including customer due diligence, identity verification, sanctions and PEP screening, transaction monitoring, source of funds and source of wealth verification, and the filing of suspicious transaction reports — are performed exclusively by the Licensed Provider selected by the User for that transaction, in accordance with the Licensed Provider's own AML/CFT policies and its regulatory authorisation.

Each Licensed Provider made available through the InstaXchange Platform is, in its own right, an obliged entity under applicable AML/CFT legislation in its jurisdiction of authorisation (including, where applicable, Regulation (EU) 2023/1114 (MiCA) and related AML/CFT obligations, or equivalent legislation in other jurisdictions).

Beneficial Owner, Money Laundering and Terrorist Financing — General Information

For the User's general awareness, the following terms are commonly used in AML/CFT regulation applicable to Licensed Providers:

A 'Beneficial Owner' is a natural person who ultimately owns or controls a customer, including, in the case of a legal entity, a natural person who directly or indirectly holds more than 25% of the shares, voting rights, or ownership interests, or otherwise exercises control over that entity.

'Money Laundering' refers to activities intended to conceal or disguise the illicit origin of funds derived from criminal activity, typically involving placement, layering, and integration.

'Terrorist Financing' refers to the provision, collection, or use of funds or assets with the intention or knowledge that they will be used to carry out terrorist acts or to support terrorist organisations.

This information is provided for general awareness only. Customer due diligence, identification, and verification in connection with a Conversion Transaction are carried out exclusively by the relevant Licensed Provider, not by InstaXchange.

Sanctions

Sanctions screening of Users in connection with a specific Conversion Transaction is performed by the relevant Licensed Provider as part of its own onboarding and ongoing monitoring procedures, in accordance with applicable international, European Union, and national sanctions regimes.

InstaXchange separately conducts its own preliminary sanctions and risk-related screening of merchants, Distribution Partners, and platform traffic, as part of its onboarding and ongoing oversight of the Platform. This screening is preliminary in nature and does not replace the screening performed by Licensed Providers. InstaXchange reserves the right to restrict, suspend, or remove access to the Platform for any user, merchant, or Distribution Partner where reasonably necessary to comply with applicable sanctions laws or to address an identified risk.

Reporting Obligations

Statutory reporting obligations, including the filing of suspicious transaction reports with the competent Financial Intelligence Unit, rest exclusively with the relevant Licensed Provider as the obliged entity. InstaXchange does not file such reports on behalf of a Licensed Provider and does not make final determinations as to whether a transaction is suspicious.

Where, as part of its own preliminary monitoring of platform traffic, InstaXchange identifies activity that may give rise to concern, InstaXchange will escalate such matters to the relevant Licensed Provider without delay and, where required by applicable law, will cooperate with and report to the competent authority within its own remit as a technology service provider.

Data Retention

InstaXchange does not collect or store User identity documentation, KYC data, or transaction monitoring records relating to a Conversion Transaction, as these are processed exclusively by the relevant Licensed Provider. InstaXchange retains only limited technical and operational data (such as session identifiers and merchant context) necessary to operate the Platform, in accordance with InstaXchange's Privacy Policy and applicable data protection legislation.

Each Licensed Provider is independently responsible for retaining AML/CFT records in accordance with its own regulatory obligations.

Internal Controls

InstaXchange maintains internal controls relating to the integrity and security of its Platform, including preliminary risk-based screening, the pre-approval of merchants and Distribution Partners, and ongoing transaction pattern monitoring at the Platform level. These controls are designed to support, and operate alongside, the AML/CFT frameworks of InstaXchange's Licensed Provider partners, and do not replace or substitute for the obligations of those Licensed Providers as obliged entities.

Contact

If You have any questions regarding this Disclaimer, please contact InstaXchange via the support channels available on the Website.