Sanctions & Forbidden Activities Policy

Last updated: 29 June 2026 · Operated by VirtuVault Technologies EOOD

Alpha Monnaies connects clients to regulated payment infrastructure across the world. With that reach comes a firm responsibility to keep our network free of financial crime. This Policy sets out the international sanctions we observe, the activities we will never support, and what we expect of everyone who uses Alpha Monnaies. It applies to all clients, partners, beneficiaries, employees, and contractors of VirtuVault Technologies EOOD ("Alpha Monnaies", "we", "us").

1. Our commitment

Alpha Monnaies is committed to full compliance with all applicable economic and trade sanctions, anti-money-laundering (AML), counter-terrorist-financing (CTF), anti-bribery, and counter-proliferation laws in every market we touch. We maintain risk-based controls, screen the parties to a payment, and work only with licensed banking and payment-institution partners who hold equivalent standards.

2. Sanctions regimes we observe

We screen against and comply with the sanctions and restrictive measures administered by, at least:

• the United Nations Security Council consolidated list;
• the European Union consolidated financial-sanctions list, and the measures of the Republic of Bulgaria;
• the United States OFAC, including the Specially Designated Nationals (SDN) list;
• the United Kingdom OFSI consolidated list;
• Switzerland (SECO) and the United Arab Emirates (the Executive Office for Control & Non-Proliferation and the UAE Local Terrorist List);
• any other regime applicable to a given transaction, currency, or correspondent.

Where regimes differ, we apply the most restrictive applicable standard.

3. Prohibited persons & territories

We will not onboard or transact with:

• any individual or entity named on, or owned or controlled (directly or indirectly, typically at or above the 50% threshold) by a party on, any applicable sanctions list;
• any person acting on behalf of a sanctioned party, or seeking to disguise such a connection;
• any person located in, ordinarily resident in, or organised under the laws of a comprehensively sanctioned territory, or a transaction with a nexus to such a territory, except under a valid licence;
• shell entities with no genuine business, or clients who refuse to provide required ownership and identity information.

4. Forbidden activities

Alpha Monnaies may never be used, directly or indirectly, in connection with:

• money laundering, terrorist financing, or proliferation financing;
• fraud, scams, phishing, business-email-compromise, or deceptive or predatory practices;
• bribery, corruption, or the evasion of tax or sanctions;
• trafficking in human beings, forced labour, or child sexual-abuse material;
• the illegal arms, weapons, ammunition, explosives, or dual-use goods trade;
• the production or distribution of illegal drugs or controlled substances;
• ransomware, malware, hacking-for-hire, or other cyber-crime, and laundering of their proceeds;
• terrorist, extremist, or violent organisations, or their financing;
• unlicensed financial services, Ponzi or pyramid schemes, or unauthorised securities or deposit-taking;
• unlicensed gambling, illegal pornography, counterfeit goods, or intellectual-property infringement;
• the sale of endangered species or protected cultural property;
• any other activity that is illegal in a relevant jurisdiction or that breaches a partner's acceptable-use requirements.

5. Restricted & high-risk activities

Some lawful activities carry elevated risk and are accepted only after enhanced due diligence, additional documentation, and partner approval — and may be declined. These include, for example, regulated virtual-asset services, money-services businesses, precious metals and stones dealers, defence and adjacent sectors, regulated gambling, adult services, and clients with politically exposed persons (PEPs) or complex offshore structures.

6. AML / CTF & screening

Before and throughout a relationship, Alpha Monnaies and its partners apply risk-based controls including:

• KYC / KYB — verifying the identity of clients and their beneficial owners;
• Sanctions, PEP, and adverse-media screening — at onboarding and on an ongoing basis, including transaction screening;
• Transaction monitoring — to detect unusual or suspicious patterns;
• Source-of-funds / source-of-wealth checks where risk warrants;
• Record-keeping for the periods required by applicable law.

7. No circumvention or facilitation

You must not use Alpha Monnaies to circumvent, or to help any person circumvent, any sanction or legal restriction — including through structuring, mislabelling the purpose or parties of a payment, using intermediaries or nominees to obscure a sanctioned interest, or routing value to a prohibited destination. Attempted circumvention is treated as a serious breach.

8. Consequences of a breach

Where we identify an actual, suspected, or attempted breach, we may — without liability to you and to the extent permitted by law — decline or delay a transaction, freeze or block funds, suspend or terminate the relationship, retain information, and make any report required to a competent authority. Sanctions and financial-crime laws can also impose civil and criminal liability directly on the persons involved.

9. Reporting suspicions

If you suspect a sanctions or financial-crime breach connected to Alpha Monnaies, tell us at once at compliance@alphamonnaies.io. Concerns about misconduct may also be raised, confidentially or anonymously, under our Whistleblower Policy. We do not retaliate against good-faith reporters. Where the law requires a suspicious-activity report to a Financial Intelligence Unit, we may be prohibited from "tipping off" the parties involved.

10. Contact

VirtuVault Technologies EOOD — Compliance
49A Bulgaria Blvd, fl. 1, Triaditsa, Sofia 1404, Bulgaria
Email: compliance@alphamonnaies.io