Anti-Money Laundering (AML) & Counter-Terrorism Financing (CTF) Policy

Next Lvl Funded PTY LTD

ABN: 685007710
Registered Address: Suite 7, Level 1, 486 Lower Heidelberg Road, Heidelberg VIC 3084, Australia
Website: https://www.nextlevelfunded.com

Introduction

Next Lvl Funded PTY LTD (“NLF”, “we”, “our”, or “the Company”) is committed to preventing money laundering,
terrorist financing, and the evasion of international sanctions. Compliance with Australian and international laws is
fundamental to maintaining our reputation, ensuring the safety of our platform, and building trust with our clients

This AML/CTF Policy outlines the procedures and measures adopted by NLF to ensure compliance with relevant
regulatory frameworks in Australia, including obligations for designated non-financial businesses and professions
(DNFBPs).

Policy Objectives

• Establish Clear Policies: Implement defined measures to address money laundering, terrorism financing, and
  sanctions evasion.

• Define Compliance Responsibilities: Outline the duties of all staff, contractors, and partners.

• Guide Daily Operations: Ensure integration of compliance into everyday business practices.

• Promote Legal Adherence: Build a culture of compliance and ethical conduct.
  

Definition of Money Laundering

In line with Australia’s Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), money
laundering involves:

• Concealing the origin of illicit funds.

• Transferring or using funds derived from criminal conduct.

• Possessing, dealing with, or facilitating the movement of illicit funds.

• Assisting others to avoid detection or prosecution

Money laundering may be committed intentionally or through reckless disregard, including failure to report
suspicious activities.

Applicable Laws and Regulations

Next Lvl Funded complies with the following regulatory obligations:

• Australian AML/CTF Act 2006 and associated Rules

• Financial Transaction Reports Act 1988 (FTR Act).

• Criminal Code Act 1995 (Cth).

• Anti-Terrorism Act 2005 (Cth).

• AUSTRAC Guidelines and reporting obligations.

• United Nations Security Council (UNSC) Sanctions adopted into Australian law.

• OECD and FATF Recommendations (international AML/CTF standards).

Investigatory Powers and Enforcement

In Australia, AUSTRAC (Australian Transaction Reports and Analysis Centre) oversees AML/CTF compliance and
suspicious matter reporting. Law enforcement agencies, including the Australian Federal Police (AFP), are
empowered to investigate breaches, while the Director of Public Prosecutions (DPP) initiates prosecutions.

Transaction Monitoring System

• Currently, NLF employs manual transaction monitoring using internal review processes

• All crypto-related transactions are processed via Confirmo (primary crypto payment processor) and
  NowPayments (secondary processor).

• Identity verification for payouts is managed through authorized payment partners.

• By 2026, NLF plans to implement an automated transaction monitoring system with enhanced anomaly
  detection.

KYC (Know Your Customer) Procedures

NLF does not directly verify client identification documents. Instead, all KYC/AML checks are conducted by our
authorized payment and compliance partners, including:

• Confirmo (crypto payments).

• NowPayments (crypto settlements).

Our partners are responsible for collecting and verifying the following:

• Full legal name.

• Date of birth.

• Residential address and country of residence.

• Valid government-issued identification (passport, national ID, or driver’s licence).

NLF only processes payouts after successful KYC/AML approval from our payment partners. Identification records
are not stored on NLF servers. Clients failing KYC verification are ineligible to receive rewards or payouts.

Prohibited Jurisdictions

NLF does not onboard, process, or engage with individuals/entities from the following sanctioned jurisdictions:

• Iran
  

• North Korea

• Myanmar (Burma)
  

• Russian Federation

• Belarus

We reserve the right to expand this list in line with AUSTRAC, OFAC, and UNSC sanction updates.

Detection of Unusual/Suspicious Transactions

• All transactions (challenge purchases and payouts) undergo manual review

• Amounts typically range between AUD $20 – $3,000 per transaction.

• Transactions inconsistent with a client’s profile, behavior, or jurisdiction are flagged for enhanced review.

Reporting Suspicious Transactions

• Suspicious activity is reported to AUSTRAC through appropriate channels.

• Record retention: All transaction data, KYC approvals, and risk assessments are stored securely for 7 years in
  compliance with the AML/CTF Act.

Risk Rating & Assessments

• Client profiles are assigned risk ratings (low, medium, high) based on jurisdiction, transaction history, and
  payment method.

• Higher-risk clients are subject to Enhanced Due Diligence (EDD).

• Ongoing risk assessments are reviewed annually or upon major regulatory updates.
  

Resolutions and Sanctions

Failure to comply with AML obligations may result in:

• Administrative penalties: warnings, fines, business restrictions.

• Criminal penalties: fines up to AUD $22 million (for corporations) and imprisonment (for individuals).

• Internal sanctions: suspension of payouts, account closures, and referral to regulators.

Employee Training

• All employees undergo annual AML/CTF training covering:
  - Identifying and reporting suspicious activity.
  - Recognizing laundering/terrorism financing typologies.
  - Understanding NLF’s internal AML/CTF procedures.

• Attendance and materials are documented.

• New laws and regulatory updates are communicated promptly.

Designated Compliance Officer

NLF has appointed a Compliance Officer, reporting directly to the CEO, responsible for:

• Overseeing AML/CTF compliance.

• Acting as liaison with AUSTRAC and regulators.

• Ensuring ongoing risk management and due diligence.