AML & Risk Disclosure

This page explains how Helix (operated by Nira Wealth Ltd, trading as Helix) handles anti-money-laundering (AML), counter-terrorism financing (CTF), sanctions, and the "Travel Rule" (FATF Recommendation 16) for transfers via the Service.

Helix is a non-custodial software tool. The Service does not hold user funds, does not transmit fiat, and is not a money services business, money transmitter, or virtual asset service provider (VASP) under UK law. As a result:

• Helix is not registered with the FCA for AML purposes (FCA registration is required only for firms carrying on regulated activities in the UK).
• Helix is not registered with HMRC for the Money Laundering Regulations 2017 (MLR17) — these apply to cryptoasset businesses registered with the FCA, which Helix is not.
• When users initiate fiat ramps (GBP/USDC, INR/USDC, etc.), the regulated partner (currently BVNK Limited) handles all AML/CTF compliance, including KYC, sanctions screening, and Travel Rule compliance. Those obligations do not transfer to Helix.

Despite being outside the scope of MLR17, we voluntarily adopt several AML measures described below, because they protect our users, our partners, and the integrity of the Service.

We block, screen, and refuse to facilitate transfers involving:

• Any person, entity, address, or jurisdiction listed on the UK HM Treasury Office of Financial Sanctions Implementation (OFSI) consolidated list.
• Any person, entity, or jurisdiction listed on the US OFAC Specially Designated Nationals (SDN) list.
• Any person, entity, or jurisdiction listed on the EU Consolidated Financial Sanctions list, the UN Security Council Consolidated list, or equivalent national lists.
• Residents or nationals of comprehensively-sanctioned jurisdictions, including: North Korea, Iran, Syria, Cuba (for US persons), Crimea / DNR / LNR regions, and any other jurisdiction that becomes comprehensively sanctioned.

We screen sender and recipient wallet addresses against the lists above on every claim creation and on every claim redemption. Hits result in automatic rejection of the operation and a hold on any associated funds. We report confirmed matches to the relevant authorities (OFSI, OFAC, NCA, etc.) as required.

The Travel Rule requires financial institutions to share originator and beneficiary information for transfers above a threshold. For crypto, the threshold is typically USD/EUR 1,000 in most jurisdictions that apply the rule.

For crypto-to-crypto transfers via Helix (no fiat involved): Helix does not currently apply the Travel Rule for purely-crypto transfers below USD 1,000. We record sender wallet, recipient wallet, amount, and timestamp for every claim, and we will share this with law enforcement on valid request.

For crypto-to-fiat or fiat-to-crypto transfers (via BVNK or similar): the regulated partner handles Travel Rule compliance. Required originator/beneficiary information is collected as part of their KYC flow.

Planned: Helix intends to integrate Notabene (a Travel Rule compliance network) for transfers above the USD 1,000 threshold, even for crypto-to-crypto. Once live, transfers above threshold will require sender and recipient counterparty information to be exchanged via Notabene's VASP-to-VASP network before settlement.

For every claim created and every claim redeemed, we:

1. Resolve the sender and recipient wallet addresses.
2. Screen those addresses against the OFAC SDN list, UK OFSI list, and the EU consolidated list (using Chainalysis, planned).
3. Screen the recipient phone number's country code against our prohibited-jurisdiction list.
4. If a hit is found, the operation is rejected and a hold is placed on any escrowed funds pending review.
5. If no hit, the operation proceeds normally.

By using the Service, you confirm and agree that:

• You will not use Helix to send or receive funds on behalf of any sanctioned person, entity, or jurisdiction.
• You will not structure transactions to evade the USD 1,000 Travel Rule threshold or any reporting threshold.
• You will not use Helix to facilitate money laundering, terrorism financing, sanctions evasion, fraud, or any other criminal activity.
• You will provide accurate information when prompted (e.g., for fiat ramps via our regulated partner).
• You understand that the Company may, in its sole discretion, freeze or reverse transactions that it reasonably believes are connected to prohibited activity, and that the Company may report such activity to relevant authorities.

If we have reason to suspect that the Service is being used for money laundering, terrorism financing, sanctions evasion, fraud, or any other criminal activity, we will:

• File a Suspicious Activity Report (SAR) with the UK National Crime Agency (NCA) via the SARs Online system, where applicable.
• Notify OFSI of any sanctions-related concerns.
• Cooperate with law enforcement on valid legal process (subpoenas, warrants, production orders).
• Where appropriate, terminate the user's access to the Service.

We do not tip off users about SARs or law-enforcement inquiries.

We retain claim records (sender, recipient, amount, timestamp, transaction hashes, related notes) for a minimum of 7 years from the date of the transaction, in line with UK statutory requirements for financial records. These records are made available to law enforcement on valid legal process.

USDC is a stablecoin issued by Circle Internet Group, Inc., a US-regulated company. Circle holds reserves in cash and short-dated US treasuries, and publishes monthly attestations. Despite this, USDC carries risk:

• Circle could become insolvent or fail to honour redemptions (low probability, but not zero).
• Regulatory action could restrict Circle's operations.
• A depeg event could see USDC trade below its $1 peg for an extended period.
• USDC on Base is a bridged representation; the bridge contract could have a vulnerability.

Helix is not a counterparty to USDC and does not guarantee its value or redeemability.

Transfers via Helix are settled on the Base Layer-2 network. The Service uses either:

• Direct USDC transfers from the sender's wallet to the recipient's wallet (no smart contract involvement; pure ERC-20 transfer), or
• An optional on-chain escrow contract (ClaimEscrow.sol) for deferred claims, with code that has been audited by [auditor TBD].

On-chain transactions are final and irreversible. If a recipient wallet is compromised or sent to the wrong address, the funds cannot be recovered. The Company does not have custody of user funds and cannot reverse any on-chain transfer.

Nothing on this page or elsewhere on the Service constitutes legal, tax, financial, or investment advice. Users are responsible for their own compliance with applicable laws, including sanctions, AML, tax reporting, and securities regulations.

For AML or compliance enquiries, contact our compliance team at compliance@helix.money.

This document is a draft and has not been reviewed by a qualified lawyer or compliance officer. It is provided for transparency and to support partner onboarding (BVNK, etc.). Do not rely on this text as legal or compliance advice.