AML / CTF Policy

TRADESHOW LIMITED is committed to preventing its services from being used to facilitate money laundering, terrorist financing, fraud, or any other financial crime. This policy sets out our approach to anti-money laundering (AML) and counter-terrorist financing (CTF) obligations.

Our AML/CTF programme is designed to comply with applicable UK legislation, including but not limited to the Proceeds of Crime Act 2002, the Terrorism Act 2000, and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations, as amended from time to time.

We are committed to:

• Implementing and maintaining effective systems and controls to prevent and detect money laundering and terrorist financing;
• Conducting customer due diligence (CDD) proportionate to the risk posed by each customer and transaction;
• Monitoring transactions for unusual or suspicious activity;
• Reporting suspicious activity to the appropriate authorities in accordance with our legal obligations;
• Training our staff to recognise and respond to AML/CTF risks;
• Cooperating fully with law enforcement and regulatory bodies in AML/CTF investigations.

We apply a risk-based approach to customer due diligence. The level of verification we require is proportionate to the assessed risk of the customer and the transaction. For lower-risk transactions such as small-value swaps, minimal information may be required. For loan applications, account creation, or higher-value transactions, we may require:

• Government-issued photo identification;
• Proof of address;
• Evidence of source of funds;
• Additional documentation as required by applicable law or our risk assessment.

We reserve the right to request additional information at any time and to delay or decline to process any transaction where satisfactory verification cannot be completed. Where enhanced due diligence (EDD) is required — for example, for politically exposed persons (PEPs) or high-value transactions — we will conduct additional checks before proceeding.

We monitor transactions and user activity for indicators of suspicious behaviour, including but not limited to:

• Transactions involving addresses associated with known illicit activity, as identified through blockchain analytics;
• Patterns consistent with layering, structuring, or smurfing;
• Transactions involving amounts or assets inconsistent with a user's stated profile;
• Unusual frequency, velocity, or patterns of transactions;
• Transactions involving jurisdictions or counterparties subject to sanctions.

Where suspicious activity is identified, we may suspend or restrict account access, hold funds pending investigation, and file a Suspicious Activity Report (SAR) with the National Crime Agency (NCA) or other relevant authority. We are legally prohibited from disclosing to users that a SAR has been filed (“tipping off”).

We do not provide services to:

• Residents, nationals, or entities domiciled in any jurisdiction subject to comprehensive UK, EU, or UN sanctions or trade embargoes;
• Individuals or entities listed on applicable sanctions lists, including the UK Consolidated List, the UN Security Council Consolidated List, or equivalent;
• Persons known to be engaged in money laundering, terrorist financing, or other financial crime;
• Shell companies or legal structures used to obscure beneficial ownership.

Where we identify that a user falls within any of the above categories, we will freeze access, report the matter to the relevant authority, and take all necessary steps to comply with our legal obligations.

We have legal obligations to report suspicious activity to the appropriate UK authorities. These obligations take precedence over any duty of confidentiality we may otherwise owe. In accordance with applicable law, we are prohibited from informing a user that a report has been made.

We cooperate fully with legitimate law enforcement requests and court orders, including the provision of account and transaction records where legally required.

We retain customer due diligence records, transaction records, and associated correspondence for a minimum of five years from the end of the relevant business relationship or transaction, in accordance with applicable legislation. Records are stored securely and access is restricted on a need-to-know basis.

For enquiries relating to this policy or to report a concern:

• Email: info@trade-lend.com
• Registered office: Office 357, Unit 5, 399-405 Oxford Street, Mayfair, London, W1C 2BU