Transactions Screening Compliance Guide

Virtual Currency Transaction Screening — Customer Guide

Delos · AML & Sanctions Compliance

Delos screens every incoming and outgoing crypto transaction against industry-standard blockchain analytics to meet AML, sanctions and counter-terrorist-financing obligations. Most transactions clear automatically. Some are paused, returned, or require additional information. This guide explains the main reasons — without disclosing the specific parameters of our risk model.

1. Why a transaction may be paused or returned

Each transaction is assessed on two independent dimensions: (i) the risk profile of the counterparty wallet and the on-chain history of the funds, and (ii) the size and pattern of the activity relative to your account. Either factor, or a combination, can trigger a hold, a return, or a request for additional documentation.

2. Counterparty categories we will not process

Transactions linked to any of the following are held and typically returned, regardless of amount:

• Sanctioned persons, entities, jurisdictions or special-measures targets (OFAC, EU, UK, UN and equivalent lists)
• Terrorist financing
• Child sexual abuse material
• Stolen funds, ransomware payments, malware operators
• Darknet markets, fraud shops, confirmed illicit organisations

3. Categories that trigger heightened scrutiny

Transactions involving the following may be paused for review and may require Source of Funds or additional documentation:

• Scam and phishing wallets
• Drug-related vendors
• Mixers, tumblers and anonymity-enhancing protocols
• Funds previously seized by, or associated with, law-enforcement actions
• Unlicensed gambling, unlicensed lending, escort services
• No-KYC exchanges, high-risk P2P platforms, cash-intensive ATMs with suspicious patterns
• Unverified or unnamed services where the operator cannot be identified

4. Direct and indirect exposure

We evaluate not only the wallet you transact with, but also where the funds came from before reaching that wallet. Funds that recently passed through a high-risk source — even via one or more intermediaries — can result in a hold even if your direct counterparty appears legitimate.

5. Activity-based triggers

Independently of counterparty risk, the following can pause a transaction:

• Transactions that are large relative to your account profile
• Sudden volume spikes versus your historical pattern
• Multiple smaller transactions in rapid succession that aggregate to a larger amount (consistent with structuring)
• Bursts of withdrawals to newly used or atypical destination wallets

6. What we may ask for

If your transaction is held, we may request Source of Funds, Source of Wealth, transaction purpose, destination wallet ownership, or refreshed KYC/KYB. Complete and timely responses are the fastest path to release.

7. How to reduce friction

• Use wallets with a clean, transparent on-chain history
• Avoid mixers, anonymity tools and unlicensed services
• Stay within your typical activity range; pre-notify us before large or unusual transactions
• Keep your KYC information current

Important. The categories and triggers above are illustrative and not exhaustive. The specific parameters of our screening logic are confidential. All decisions remain at Delos’ sole discretion and are made on a case-by-case basis. This guide does not modify the Delos Terms of Service or any applicable agreement.