AML & Risk Control Policy

This AML and Risk Control Policy describes the measures implemented by ExcaliburHQ B.V. ("Company") to prevent misuse of the VoidCalls platform for:

• Money laundering
• Terrorist financing
• Sanctions evasion
• Fraudulent or unlawful activity
• Abuse of affiliate or payment systems

VoidCalls is a non-custodial AI-powered blockchain analytics and signal discovery platform. Risk controls are implemented at the service access level, infrastructure level, payment level, and blockchain interaction level rather than through traditional custodial onboarding systems.

VoidCalls:

• Does not require custody of user assets
• Does not process fiat payments directly
• Does not act as an exchange, broker, or financial intermediary
• Does not provide regulated investment services
• Provides AI-powered analytics, memecoin discovery tools, market intelligence, and blockchain-related software services

Users interact directly with blockchain infrastructure using self-custodied wallets.

ExcaliburHQ B.V. provides software services only and does not perform regulated financial services requiring licensing under Dutch or EU financial supervision regimes.

Nevertheless, the Company voluntarily applies proportionate AML and risk control measures aligned with its operational structure, blockchain-related risks, sanctions compliance obligations, and fraud prevention objectives.

Because the Platform operates on a non-custodial basis, AML and fraud mitigation measures are based on:

• Geographic access controls
• Sanctions screening
• Blockchain monitoring
• Wallet interaction analysis
• Abuse detection systems
• Payment monitoring
• Affiliate fraud prevention
• Service-level restriction capabilities

The Company does not operate traditional custodial onboarding systems.

The Platform is not available to individuals or entities located in, incorporated in, or acting on behalf of persons located in jurisdictions subject to comprehensive international sanctions. This includes, but is not limited to, North Korea, Iran, Syria, Cuba, and Russia (to the extent restricted under EU sanctions).

Sanctions frameworks considered include EU sanctions lists, United Nations sanctions lists, and U.S. OFAC sanctions lists.

The Company reserves the right to restrict access, block wallet interactions, deny service availability, or suspend promotional access where sanctions exposure is identified.

User location may be determined through IP-based detection systems, wallet analysis, technical fingerprinting, VPN/proxy detection systems, and fraud prevention technologies.

Users may not use VPNs, proxies, Tor, or similar tools to conceal location, attempt to bypass sanctions or geographic restrictions, access the Platform on behalf of restricted persons, or manipulate geographic detection systems.

Where circumvention is detected, the Company may block frontend access, restrict API usage, disable promotional systems, prevent access to platform-controlled infrastructure, or permanently restrict access.

Because the Platform operates without custodial infrastructure, enforcement measures operate primarily at the service and infrastructure level. Where prohibited or suspicious activity is detected, the Company may:

• block IP ranges
• restrict frontend access
• disable affiliate systems
• restrict wallet interactions
• prevent access to APIs or platform services
• limit interaction with platform-controlled systems

Although VoidCalls does not conduct routine onboarding KYC procedures, the Company reserves the right to request additional information where credible suspicion of unlawful activity exists, payment fraud is detected, affiliate abuse is suspected, blockchain activity raises fraud indicators, regulatory exposure increases, or legal requests are received.

Failure to cooperate may result in restriction of services, affiliate removal, suspension of payouts, or permanent access termination.

The Company may review publicly available blockchain data, wallet interaction patterns, transaction flows, links to sanctioned wallet addresses, affiliate payout structures, suspicious blockchain behavior, and interactions with known illicit actors.

Monitoring is limited to publicly accessible blockchain information, technical interaction logs, and payment-related infrastructure data.

VoidCalls may implement automated systems to identify self-referrals, abusive commission loops, fake traffic, bot-generated activity, suspicious wallet behavior, fraudulent promotional activity, and payment abuse.

The Company may reverse affiliate payouts, disable referral systems, terminate affiliate access, or restrict promotional visibility where abuse is detected.

Where suspected unlawful conduct is identified, the Company may restrict access to services, preserve technical records, suspend affiliate or payment systems, and report suspected unlawful conduct to competent authorities where required or deemed appropriate under applicable law.

The Company maintains records relating to corporate governance, platform access logs, payment infrastructure, security investigations, affiliate systems, fraud investigations, and compliance decisions. Records are retained in accordance with applicable law.

AML and risk oversight is conducted by senior management. Given the non-custodial structure of the Platform, compliance measures are designed to remain proportionate to the operational model, technological structure, and risk exposure of the business.

This Policy may be updated periodically to reflect regulatory developments, risk landscape changes, modifications to the Platform, payment infrastructure changes, or affiliate system updates. The latest version will be published on the Platform.