Fraud Policy

This Fraud Policy explains how APEXTRADE Sp. z o.o., trading as APEXTRADE ("we", "us"), detects and prevents fraud, money laundering, and terrorist financing on our platform, what we expect from users, and how to report suspicious activity. It supplements our Terms & Conditions and applies to every account holder and every transaction processed through our Services.

We maintain an anti‑money‑laundering and counter‑terrorist‑financing ("AML/CTF") programme designed to comply with the Polish Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing, EU Anti‑Money Laundering Directives, applicable EU and UN sanctions regimes, and — as it comes into force for our activities — Regulation (EU) 2023/1114 (MiCA) and the associated EU AML framework. As disclosed in our Terms & Conditions, we currently operate under a virtual‑currency‑service registration rather than full CASP authorisation, and our AML/CTF controls are calibrated accordingly and reviewed as our regulatory status evolves.

Before you can deposit, trade, or withdraw, we verify your identity ("KYC") using government‑issued identification and other supporting documentation. We apply:

• Standard due diligence for the majority of retail users;
• Enhanced due diligence for higher‑risk users, including politically exposed persons (PEPs), their family members and known close associates, users connected to high‑risk jurisdictions, and users with unusual transaction patterns; and
• Ongoing monitoring to keep customer information current and to reassess risk over the lifetime of the relationship.

We use automated and manual controls to monitor deposits, withdrawals, and trading activity for indicators of fraud, money laundering, or terrorist financing, including unusual transaction size or frequency, structuring, links to sanctioned or high‑risk wallet addresses, and deviations from your expected activity profile. Flagged activity may result in a transaction being held pending review, or in a request for additional information from you.

Where we identify activity that raises reasonable grounds for suspicion, we are legally required to file a report with Poland's Financial Intelligence Unit (Generalny Inspektor Informacji Finansowej, "GIIF") without informing the user concerned ("tipping‑off" is prohibited by law). We cannot confirm or deny whether a report has been filed in respect of any account.

The following are strictly prohibited on our platform:

• money laundering or terrorist financing, or attempting to disguise the origin of funds;
• using stolen funds, stolen identity documents, or a fraudulently obtained account;
• phishing, account takeover, social engineering, or unauthorised access to another user's account;
• market manipulation, including wash trading and spoofing;
• use of the Services by, or on behalf of, sanctioned individuals or entities; and
• any attempt to circumvent verification, monitoring, or sanctions‑screening controls.

Where we have reasonable grounds to suspect fraud, money laundering, sanctions exposure, or a breach of this Policy, we may freeze an account, hold a transaction, or restrict withdrawals for the period necessary to investigate and to comply with our legal obligations, including where instructed by GIIF or another competent authority. We will restore normal service as soon as permitted once our review is complete.

To help keep your account safe, you should:

• use a strong, unique password and enable two‑factor authentication;
• never share your login credentials, verification codes, or recovery details with anyone, including people claiming to represent APEXTRADE;
• verify that any website or communication claiming to be from APEXTRADE uses our official domain and channels; and
• report lost or stolen devices, or any suspected compromise of your account, immediately.

If you suspect fraud, unauthorised access to your account, or a scam impersonating APEXTRADE, contact us immediately at info@tiontrade.com with as much detail as possible. We investigate all reports promptly and, where appropriate, escalate matters to law enforcement.

We cooperate with GIIF, the Polish Financial Supervision Authority (KNF), law enforcement, and courts of competent jurisdiction, and will disclose information as required by a valid legal request or court order.

We screen users and transactions against EU, UN, and other applicable sanctions lists. We do not knowingly provide Services to individuals or entities that are the target of sanctions, or that are located in a jurisdiction subject to comprehensive sanctions restricting our ability to provide Services.

We review this Fraud Policy periodically and update it to reflect changes in law, regulatory guidance, and our risk assessment. The current version is always available on this page.