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AML / CTF POLICY

StixRamp
Operated by KALYXIO (SASU)

1. Purpose of this Policy

This Anti-Money Laundering and Counter-Terrorist Financing Policy (“AML/CTF Policy”) describes the measures implemented by KALYXIO, operator of StixRamp, to prevent money laundering, terrorist financing, and other illicit activities.

This policy is designed in accordance with:

  • EU AML Directives

  • French AML regulations

  • FATF recommendations

  • A risk-based and proportional approach, reflecting the actual role of StixRamp.

2. Company Information

Company: KALYXIO
Legal form: SASU (Simplified Joint-Stock Company – single shareholder)
Registered address:
195 Rue Pierre et Marie Curie
27310 Bourg-Achard
France

RCS: 999 024 862 R.C.S. Bernay
VAT: FR26999024862

Product / Trade name: StixRamp

3. Nature of the StixRamp Service

StixRamp operates as a technical on-ramp aggregator and introducer.

StixRamp:

  • Provides a technical interface to compare and route users to third-party crypto on-ramp providers

  • Acts as a technical integrator and commercial introducer

  • Does not process payments

  • Does not execute transactions

  • Does not hold or custody fiat or crypto assets

  • Does not set prices, fees, or exchange rates

  • Does not conduct KYC or AML checks on end users

All fiat-to-crypto transactions are executed directly between the user and the selected third-party on-ramp provider.

4. Relationship with Third-Party Providers

StixRamp integrates regulated or compliance-oriented third-party on-ramp providers (e.g. Transak, Mercuryo, Cryptix, FinchPay).

Each provider is solely responsible for:

  • Customer identification (KYC)

  • Transaction monitoring

  • Sanctions screening

  • AML/CTF compliance

  • Regulatory reporting

StixRamp relies on the AML/CTF frameworks of its partners and does not duplicate or override their compliance processes.

5. Risk Assessment

5.1 Risk Profile

Given its limited role, StixRamp presents a low AML/CTF risk profile, as it:

  • Does not touch customer funds

  • Does not control transaction flows

  • Does not onboard users directly

  • Does not allow anonymous execution of transactions

5.2 Identified Risks

  • Misuse of the platform as a redirection layer

  • Reputational risk via third-party misconduct

5.3 Risk Mitigation Measures

  • Partner due diligence

  • Clear contractual allocation of compliance responsibilities

  • Platform-level monitoring of abnormal technical activity

  • Immediate suspension of integrations in case of compliance concerns

6. Customer Due Diligence (CDD)

StixRamp does not perform Customer Due Diligence.

All CDD obligations are performed by integrated on-ramp providers, including:

  • Identity verification

  • Source of funds checks

  • Enhanced due diligence when required

Users are clearly informed that they will be subject to KYC/AML checks by the selected provider.

7. Transaction Monitoring

StixRamp does not monitor financial transactions, as it does not process or execute them.

However, StixRamp may:

  • Monitor technical usage patterns

  • Detect abuse, automated misuse, or suspicious platform behavior

  • Suspend access to providers or users in case of abnormal activity

8. Sanctions and Prohibited Jurisdictions

StixRamp does not actively screen users against sanctions lists.

Sanctions screening and geographic restrictions are fully enforced by the on-ramp providers, in accordance with their regulatory obligations.

StixRamp does not intentionally target or promote services to sanctioned jurisdictions.

9. Record Keeping

StixRamp maintains limited technical records, including:

  • Logs of redirection events

  • Timestamps and technical identifiers

  • Non-sensitive operational data

No financial transaction records or KYC documents are stored by StixRamp.

Data retention complies with GDPR and applicable legal requirements.

10. Reporting of Suspicious Activity

As StixRamp does not process transactions, it does not file Suspicious Activity Reports (SARs).

If suspicious behavior is identified at a technical level:

  • The relevant partner may be notified

  • Access may be restricted or suspended

  • Cooperation with competent authorities may occur when legally required

11. Governance and Responsibility

The AML/CTF framework is overseen by the Founder and Director of KALYXIO, who is responsible for:

  • Maintaining this policy

  • Partner selection and oversight

  • Responding to compliance inquiries

  • Periodic review of AML risks

12. Training

Given the size and structure of KALYXIO:

  • No dedicated AML staff is required

  • The director remains informed of AML/CTF regulatory developments

  • Compliance awareness is maintained proportionally

13. Policy Review

This AML/CTF Policy is reviewed:

  • At least annually

  • Upon material changes to the business model

  • Upon regulatory or partner requirements

14. Contact

For AML / compliance matters:

Email: contact@stixramp.com
Company: KALYXIO – StixRamp