AML & Compliance Statement

Xavion Capital is a business services intermediary providing banking placement, company formation, and crypto advisory services to international businesses and founders. We introduce clients to regulated banking institutions, electronic money institutions (EMIs), payment service providers, licensed company formation agents, and crypto licensing advisors within our global network.

Our Role

Xavion Capital acts solely as an intermediary and introducer. We do not hold client funds, accept deposits, operate as a payment institution, or conduct any activity that constitutes a regulated financial service. We do not provide investment advice, legal advice, or tax advice.

Our services are limited to:

• Banking Placement — assessing client profiles, preparing documentation, and introducing clients to regulated banks and EMIs suited to their profile and jurisdiction.
• Company Formation — coordinating incorporation through licensed formation agents and corporate service providers across multiple jurisdictions.
• Crypto Advisory — guiding clients through crypto licensing processes and introducing them to appropriate advisors, VASPs, and regulated institutions.
• Supporting clients through onboarding and setup processes across all service lines.

Know Your Business (KYB) and Know Your Customer (KYC)

Prior to providing services or making any introduction, Xavion Capital conducts an initial client profile assessment. As part of this process, we collect and review:

• Proof of identity for all directors, shareholders, and ultimate beneficial owners (UBOs).
• Proof of address and residency documentation.
• Corporate documentation including certificates of incorporation, articles of association, and shareholder registers.
• A clear description of the client's business activities, source of funds, and source of wealth.
• The intended purpose of the banking relationship, company structure, or crypto licence being sought.
• Any existing banking, financial service, or regulatory relationships.

We do not provide services or introduce clients to partner institutions where we are unable to satisfy ourselves that:

• The identity of all relevant persons can be verified.
• The source of funds and source of wealth are consistent and explainable.
• The business activity is legal in the relevant jurisdiction(s) of operation.
• The purpose of the engagement is legitimate and transparent.

Sanctions Screening

Xavion Capital screens all clients and their associated parties against the following sanctions lists before commencing any engagement:

• United Nations Security Council Consolidated Sanctions List.
• OFAC (US Office of Foreign Assets Control) Specially Designated Nationals (SDN) List.
• UK HM Treasury Financial Sanctions List.
• European Union Consolidated Sanctions List.

We do not work with clients who appear on any applicable sanctions list, or who are subject to asset freezes, travel bans, or other restrictive measures under the above regimes.

Jurisdictions We Do Not Work With

Xavion Capital does not introduce clients or facilitate services for entities or individuals with material connections to the following categories of jurisdiction:

• Countries subject to comprehensive UN, EU, UK, or US sanctions programmes, including but not limited to North Korea, Iran, Syria, and Cuba.
• Jurisdictions identified by FATF as High-Risk or under Increased Monitoring (the FATF Grey List and Black List), where the risk profile cannot be adequately mitigated.
• Jurisdictions designated as non-cooperative by relevant international bodies where independent verification of client identity or source of funds is not possible.

This list is reviewed periodically and updated in line with changes to applicable sanctions regimes and FATF guidance.

Our Partners' Independent AML Obligations

All banking institutions, EMIs, payment service providers, corporate service providers, and licensing bodies within the Xavion Capital network are independently regulated by their respective national financial or corporate regulators. These institutions and agents conduct their own full KYC, AML, and sanctions screening processes in accordance with their own regulatory obligations before accepting any client.

Our network includes institutions and agents regulated by:

• The Financial Conduct Authority (FCA), United Kingdom.
• The Bank of Lithuania.
• The Malta Financial Services Authority (MFSA).
• The Monetary Authority of Singapore (MAS).
• The Hong Kong Monetary Authority (HKMA).
• The National Bank of Georgia (NBG).
• The Financial Supervisory Commission (FSC), Cook Islands.
• The Bank of Mauritius.
• Relevant Caribbean offshore banking regulators.
• The Superintendency of Banks of Panama.
• The International Financial Services Commission (IFSC), Belize.
• Companies House (UK) and equivalent corporate registries across multiple jurisdictions.

Xavion Capital's introduction of a client does not guarantee or imply that the receiving institution, agent, or licensing body will accept that client. All final acceptance, compliance, and onboarding decisions rest solely with the receiving party.

What We Do Not Do

Xavion Capital does not:

• Make final KYC, AML, or sanctions compliance determinations on behalf of any regulated institution.
• Hold, transfer, or custody client funds at any stage.
• Provide guarantees of account opening, company formation, or licence approval outcomes.
• Introduce clients with the purpose of circumventing sanctions, regulatory requirements, or applicable law.
• Work with clients or structures where the ultimate beneficial owner cannot be identified and verified.
• Act as a money services business, payment processor, or regulated financial intermediary.

Compliance Queries

For any compliance-related enquiries, including requests from partner institutions, corporate registries, or regulatory bodies, please contact:

compliance@xavioncapital.com

This statement was last reviewed in June 2026. Xavion Capital reserves the right to update this statement at any time in line with changes to applicable laws, regulations, and sanctions regimes.