Anti-Money Laundering Policy

Last updated: March 2026

1. Commitment

Ondex Labs LLC (“Ondex”) is committed to preventing money laundering, terrorist financing, and other financial crimes. We comply with applicable anti-money laundering (AML) laws and regulations, including the Bank Secrecy Act (BSA), USA PATRIOT Act, and Office of Foreign Assets Control (OFAC) sanctions requirements.

2. Self-Custodial Nature

Ondex is a non-custodial, self-custodial application. We do not:

  • Hold, control, or have access to user funds
  • Process fiat currency transactions directly (fiat services are provided by licensed third-party partners)
  • Act as a money services business, money transmitter, or virtual asset service provider
  • Maintain custody of any user’s private keys or digital assets

Users maintain sole control over their private keys and are solely responsible for all transactions conducted through their wallets.

3. Blocked Jurisdictions

In compliance with international sanctions programs, the App may not be used from the following jurisdictions:

  • OFAC Comprehensive Sanctions: North Korea, Iran, Syria, Cuba
  • Conflict regions: Crimea, Donetsk, and Luhansk regions of Ukraine
  • Any other jurisdiction where cryptocurrency wallets are prohibited by law

On-ramp and off-ramp services provided through third-party partners may have additional geographic restrictions, including but not limited to limitations in certain U.S. states (e.g., New York, Hawaii), China, and Russia. These restrictions are determined by the respective service providers.

4. Sanctions Screening

Ondex implements the following sanctions compliance measures:

  • IP-based geolocation checks to block access from sanctioned jurisdictions
  • Monitoring of OFAC Specially Designated Nationals (SDN) list updates
  • Blocking of wallet addresses identified on sanctions lists when interacting with Ondex services
  • Cooperation with law enforcement agencies when required by law

5. KYC Policy

As a self-custodial wallet, Ondex does not directly collect Know Your Customer (KYC) documentation for basic wallet functionality. Our KYC approach follows a tiered system:

  • Tier 1 — Basic Wallet: No KYC required. Users can create wallets, send/receive XRP and tokens, trade on the DEX, and use social features without providing identity documentation.
  • Tier 2 — Fiat On/Off-Ramp: KYC is collected and verified by our licensed third-party fiat partners (e.g., Meld) in accordance with their own compliance programs. Ondex does not store this KYC data.
  • Tier 3 — Enhanced Due Diligence: For transactions or patterns that trigger enhanced monitoring thresholds, additional verification may be requested through our third-party partners.

6. Compliance Measures

We implement the following measures:

  • Cooperation with law enforcement authorities when legally required (subpoenas, court orders)
  • Transaction monitoring for suspicious patterns and unusually large volumes
  • Compliance with applicable sanctions lists (OFAC SDN, EU, UN)
  • Regular review and updates of our compliance program in response to evolving regulations
  • Staff training on AML/CFT compliance obligations
  • Record-keeping in accordance with applicable legal requirements

7. User Obligations

By using the App, you represent and warrant that:

  • You will not use the App for money laundering, terrorist financing, or any other illegal activity
  • You are not a resident or national of a Blocked Jurisdiction listed in Section 3
  • You are not listed on any sanctions list (OFAC SDN, EU, UN, or equivalent)
  • You comply with all applicable laws and regulations in your jurisdiction
  • You will not attempt to circumvent any compliance measures implemented by the App
  • You will report any suspicious activity you encounter through the App to compliance@ondex.money

8. Reporting

If you suspect any illegal activity, money laundering, or sanctions violations, please report it immediately to compliance@ondex.money. All reports are treated confidentially and investigated promptly.

Ondex will file Suspicious Activity Reports (SARs) with the Financial Crimes Enforcement Network (FinCEN) when required by law.

9. Updates

This policy is reviewed and updated regularly to ensure compliance with evolving regulations and sanctions programs. Material changes will be communicated through the App or our website.