AML and Fraud Prevention

1. Purpose

Veritex applies risk-based controls to reduce fraud, misuse, sanctions risk, money laundering risk, duplicate settlement attempts, and abuse of certificate buyback functionality.

2. Controls

• Manual review of certificate buyback requests when automated settlement is unavailable or risky.
• Provider status tracking, settlement identifiers, and error history.
• Certificate locking to prevent duplicate buyback or simultaneous VOTE claim.
• Request rejection and certificate release when checks fail.
• Ability to request additional information from the user.

3. Restrictions

The operator may refuse service for sanctioned persons, prohibited jurisdictions, suspicious activity, mismatched settlement details, unlawful purposes, or activity that violates payment provider rules.

4. Records

Veritex may keep operational records of certificate actions, buyback requests, provider statuses, errors, and related support communications for compliance and dispute handling.