AML / KYC Policy

1. Purpose

The XInvest service is operated by IMPULSS LTD, a company registered in the United Kingdom, with its registered office at 2 Catkin Walk, Rugeley, WS15 2NS, United Kingdom (“XInvest”, “we”, “us”). We are committed to operating our business with integrity and to preventing the misuse of our Service for money laundering, terrorism financing, fraud, sanctions evasion or any other unlawful purpose. This Policy explains the controls we apply at the level appropriate for the Service we provide.

2. Nature of the Service — Important Context

XInvest is an information and signal service. XInvest is not a broker, dealer, exchange, payment institution, e-money issuer or any other type of regulated financial intermediary. Specifically:

• we do not accept, hold, transfer or exchange client funds;
• we do not open or operate trading accounts on behalf of users;
• we do not place or execute orders on financial markets;
• trading takes place exclusively between the user and the user’s chosen broker, on the user’s own account.

Because we are not a financial institution, we are not required to perform full customer due diligence (“KYC”) of the type imposed on banks, brokers or exchanges. However, we voluntarily apply the proportionate controls described below to reduce the risk that our Service is misused.

3. Payments

All subscription and VIP payments are processed by independent, regulated payment service providers. Those providers carry out their own customer-identification, fraud-prevention and AML screening as required by their licences and applicable law. XInvest does not receive or hold funds outside this regulated payment flow, and does not store full payment-card details.

4. Account-Level Controls

To use the Service, users must:

• provide a valid email address and, where required, a valid Telegram account;
• be at least 18 years old (or the age of majority in their jurisdiction);
• not be located in a jurisdiction subject to comprehensive international sanctions, and not appear on relevant sanctions or terrorism-financing lists;
• not use the Service in breach of applicable law or for any unlawful purpose.

5. Restricted Persons and Jurisdictions

The Service is not offered to, and may not be used by:

• persons or entities subject to UN, EU, UK, US (OFAC), or other applicable financial sanctions;
• persons or entities included on relevant terrorism-financing lists;
• residents of jurisdictions where the receipt or distribution of trading signals or related information is prohibited or restricted, or where it would require us to obtain a licence we do not hold.

If we identify that a user falls within any of the above categories, we may suspend or terminate their access without notice and refuse refunds where law permits.

6. Risk-Based Monitoring

We monitor for indicators of suspicious or abusive behaviour, including (without limitation):

• multiple chargebacks or payment-fraud signals;
• unusual patterns suggesting account or subscription resale;
• attempts to bypass geo-restrictions or sanctions checks;
• requests inconsistent with legitimate use of an information service (e.g. attempts to push transactions through XInvest as if it were a broker).

Where appropriate, we may request additional information from the user, restrict access, suspend the account, terminate the subscription and/or report relevant matters to competent authorities, in accordance with applicable law.

7. Reliance on Regulated Counterparties

Users carry out actual trading and money movements with their own brokers and payment providers. Those entities are responsible for their own KYC, AML and counter-terrorism-financing programmes. XInvest does not assume their regulatory obligations and is not a substitute for them.

8. User Cooperation

By using the Service, you confirm that you are using it in compliance with all applicable laws (including AML and sanctions laws), that the funds used to purchase any subscription are derived from legitimate sources, and that you are not acting on behalf of any restricted person. You agree to provide reasonable cooperation if we make a lawful request for additional information.

9. Reporting and Cooperation with Authorities

We will cooperate with competent law-enforcement, regulatory and tax authorities where required, including by responding to lawful information requests and court orders. Disclosures of personal data in this context are made in accordance with our Privacy Policy and applicable law.

10. Changes

We may update this Policy from time to time to reflect changes in regulation, our business or our risk assessment. The “Last updated” date at the top reflects the latest version.

11. Contact

For questions about this AML / KYC Policy, contact support@xinvestnews.com.