# Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Policy

This Anti-Money Laundering and Countering the Financing of Terrorism (“AML/CFT”) Policy describes the internal standards, procedures, and controls implemented by CZR Exchange and its affiliated entities (collectively, “CZR,” “CZR Exchange,” “we,” “us,” or “our”) to prevent, detect, and report money laundering, terrorist financing, sanctions evasion, fraud, and other financial crimes.

## CZR’s AML/CFT Commitment and Principles

CZR Exchange is committed to maintaining a robust, risk-based AML/CFT compliance framework aligned with:

* Financial Action Task Force (FATF) Recommendations
* Applicable anti-money laundering and counter-terrorism financing laws
* Sanctions and trade control regulations
* Travel Rule obligations where applicable
* Regulatory expectations applicable to Virtual Asset Service Providers (VASPs)

Our AML/CFT program is designed to:

* Prevent misuse of the Platform for illicit activity
* Identify and mitigate financial crime risk
* Ensure regulatory compliance across applicable jurisdictions• Cooperate fully with law enforcement and competent authorities

We apply a risk-based, multi-layered control system incorporating customer due diligence, transaction monitoring, sanctions screening, and enhanced due diligence procedures.