1. Purpose and status

This policy describes the compliance-control framework used by ODEON KAPITAL AG for the Odeon Kapitals platform. It is informational and does not replace the Terms of Service, product terms, or obligations imposed by applicable law.

Company registration does not by itself represent a financial-services license. Product and jurisdiction availability should not be interpreted as a claim of authorization by a regulator unless a specific authorization is separately identified.

2. Risk-based control framework

Controls are selected according to the account, product, jurisdiction, transaction, provider, and identified risk. The framework may include:

• Identity and document verification
• Source-of-funds and account-purpose information
• Sanctions, watchlist, and risk screening
• Funding, withdrawal, transaction, and account-event review
• Escalation, restriction, investigation, and record keeping
• Legal, privacy, security, and product acceptance records

The scope and timing of a control may vary. Completion of a check does not guarantee continuing access to every product or service.

3. Customer due diligence

3.1 Identity verification

Users may be required to provide:

• Legal name, date of birth, country, and residential address
• Government-issued photo identification
• Proof of address or other corroborating information
• Tax, employment, occupation, and account-purpose information
• Source-of-funds or source-of-wealth information where relevant
• Corporate ownership and control information for business relationships

Documents may be checked for validity, consistency, authenticity indicators, and risk signals.

3.2 Enhanced review

Additional information or review may be required for higher-risk circumstances, including material inconsistencies, unusual funding, higher-risk jurisdictions, complex ownership, sanctions exposure, or politically exposed persons.

Politically exposed persons are not described as automatically prohibited by this policy; they may require enhanced due diligence and approval where service is legally permitted.

4. Financial-crime prevention

The platform may use risk-based measures intended to identify and respond to money laundering, terrorist financing, fraud, sanctions evasion, identity misuse, and other prohibited activity.

Measures may include:

• Screening submitted identity and account information
• Reviewing transaction patterns and rapid movement of funds
• Comparing funding sources and withdrawal destinations
• Restricting activity pending verification or investigation
• Requesting explanations and supporting records
• Reporting information where a valid legal obligation applies

We do not disclose confidential monitoring rules, thresholds, or investigative methods.

5. Sanctions and restricted activity

Services may be declined, limited, suspended, or terminated where a person, entity, jurisdiction, transaction, or activity is prohibited by applicable sanctions, provider restrictions, or law.

Users may not use the platform to conceal beneficial ownership, evade a restriction, transact for an undisclosed third party, or provide false information about a payment or destination.

6. Market and platform integrity

Conduct that may harm users, markets, or platform integrity is prohibited, including:

• Fraud, misrepresentation, and account impersonation
• Manipulation, wash activity, spoofing, or coordinated abuse
• Use of confidential information contrary to applicable law
• Circumvention of order, funding, withdrawal, promotion, or risk controls
• Unauthorized automated access or interference with platform systems

Potential violations may result in order rejection, account restrictions, preservation of relevant records, or referral where legally required.

7. Funding and withdrawal controls

Deposits and withdrawals may be reviewed for account ownership, identity status, transfer references, available funds, reserved obligations, suspicious activity, and consistency with the account profile.

A request can remain pending, be returned, or require additional information. Product-specific restrictions, including an accepted liquidity advance or fixed term, may also affect availability.

8. Data protection and security

Compliance processing uses personal information as described in the Privacy Policy. Access to identity, transaction, acceptance, and security records is restricted according to operational role and system permissions.

Controls may include encryption, authenticated access, event recording, optional multi-factor authentication, and monitoring intended to detect unauthorized activity. This policy does not claim a certification, audit result, or testing program that is not separately documented.

9. Records and retention

Records may be maintained for:

• Identity verification and account-risk decisions
• Orders, positions, deposits, withdrawals, and account events
• Legal-document and cookie choices
• Support, investigation, and security communications
• Restrictions, escalations, and legally required reports

Retention depends on the record, service, account status, investigation, provider, and applicable legal requirement. Access is limited to legitimate operational, security, legal, and support purposes.

10. Third-party providers

Identity, banking, market-data, infrastructure, communications, and support providers may be reviewed before and during use. The level of review depends on the service, data access, operational importance, and identified risk.

Provider use does not transfer a user's obligations or eliminate risks created by outages, errors, financial failure, or changing provider restrictions.

11. Concerns, cooperation, and review

Users and staff should report suspected fraud, account misuse, security incidents, or compliance concerns through an appropriate support or compliance channel. Reports are assessed according to available information and applicable obligations.

This policy is reviewed when material product, legal, provider, or control changes require an update. A new public version and effective date are used for material revisions.