Anti-Money Laundering and Counter-Financing of Terrorism
Effective date: 1 August 2025 · Last reviewed: 1 July 2026
This Anti-Money Laundering and Counter-Financing of Terrorism Policy ("AML/CFT Policy") describes the measures implemented by MobiusDev Ltd. (Registration No. 2026-00574), an International Business Company (IBC) incorporated in Saint Lucia and operating the Premium NFT marketplace at pnmarketplace.com, to prevent, detect, and report money laundering, terrorist financing, and other financial crime.
MobiusDev Ltd. is committed to compliance with applicable anti-money laundering and counter-terrorist financing laws of Saint Lucia, FATF Recommendations, and internationally recognised sanctions regimes including OFAC, EU, and UN consolidated lists.
This Policy applies to:
The Platform exclusively facilitates peer-to-peer secondary-market trading of non-fungible tokens (NFTs) on the Ethereum blockchain. We do not handle fiat currency, act as a custodian of digital assets, or operate a crypto exchange. All payments are made directly on-chain by users from their own self-custodial wallets.
MobiusDev Ltd. has conducted a documented risk assessment of its business model and categorises the inherent AML/CFT risk as Medium, based on the following factors:
The risk assessment is reviewed at least annually and updated following any material change in business model, regulatory guidance, or threat landscape.
3.1 Standard CDD: All users authenticate via their self-custodial blockchain wallet. We record the wallet address as the customer identifier. Wallet addresses are public, pseudonymous identifiers linked to all on-chain activity.
3.2 Wallet Screening: All wallet addresses connecting to the Platform are cross-referenced against publicly available sanctions lists and on-chain risk indicators. We screen against:
The Platform intends to integrate a third-party blockchain analytics service to enhance automated screening capabilities. Pending such integration, manual review processes are applied to transactions above defined thresholds.
3.3 Enhanced Due Diligence (EDD): Enhanced due diligence is applied in the following circumstances:
EDD may require the user to provide identity documentation, proof of source of funds, and other information as required by applicable law. We reserve the right to suspend or terminate access pending EDD completion.
MobiusDev Ltd. maintains a zero-tolerance policy toward transactions involving sanctioned individuals, entities, or jurisdictions. We do not provide services to users who are:
Access to the Platform is technically restricted by IP geolocation for jurisdictions under comprehensive sanctions. However, users represent and warrant that they are not subject to sanctions regardless of technical access. We may terminate access and report to competent authorities if sanctions violations are detected.
We employ ongoing transaction monitoring to detect unusual or suspicious activity. Our monitoring programme flags the following patterns for review:
Flagged transactions are reviewed by our Compliance team. We reserve the right to freeze, cancel, or reverse listings and to report suspicious activity to the competent financial intelligence authority in Saint Lucia or other relevant authority as required by applicable law.
MobiusDev Ltd. has appointed a Money Laundering Reporting Officer (MLRO). All employees and contractors who suspect money laundering or terrorist financing must report their suspicion to the MLRO without delay and without tipping off the suspected person. The MLRO will assess each report and, where appropriate, file a Suspicious Activity Report with the relevant competent authority. Reports are submitted within the timeframes required by applicable law.
Filing a SAR or providing information to a competent authority in good faith is protected under applicable law and does not constitute a breach of any confidentiality obligation.
We retain the following records for a minimum period of five (5) years from the date of the transaction or the end of the business relationship, whichever is later:
All personnel with access to customer data or transactional systems receive AML/CFT training at onboarding and annually thereafter. Training covers: recognition of red flags, reporting obligations, sanctions compliance, and the consequences of failing to report suspicious activity.
Where applicable regulations require transmission of originator and beneficiary information for virtual asset transfers (the "Travel Rule"), MobiusDev Ltd. implements procedures to collect and transmit this information. We co-operate with our counterparts (receiving virtual asset service providers) to ensure compliance with FATF Recommendation 16.
The Platform may not be used in connection with: ransomware payments; darknet market proceeds; drug trafficking proceeds; human trafficking proceeds; weapons proliferation financing; or any other activity prohibited by applicable law. Any wallet address linked to such activities will be permanently banned and reported to relevant authorities.
Questions regarding this Policy, requests to report suspicious activity, or compliance enquiries may be directed to:
MobiusDev Ltd. — Compliance DepartmentThis Policy is reviewed at least annually by the Board of Directors of MobiusDev Ltd. and updated as necessary to reflect changes in law, regulation, or business practice.