AML Policy

Last Updated: April 2026

Apex Advisors LLC is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. Our operations in Dubai, United Arab Emirates (DMCC Free Zone), and Los Angeles, California, United States are subject to the laws and regulatory requirements applicable to each entity and its activities, including applicable anti-money laundering, counter-terrorist financing, and sanctions requirements.

1. Our Commitment

We do not tolerate money laundering, terrorist financing, or any other form of illicit financial activity. While we do not directly process payments (all transactions run through our Partners' integrated Stripe accounts), we actively manage the merchant profiles and take our responsibility to safeguard the financial ecosystem seriously.

2. Know Your Customer (KYC)

Before any Partner is onboarded and connected to a Merchant via Apexlink, we conduct thorough due diligence:

  • Identity Verification: Collection of valid government-issued ID for individuals or directors.
  • Business Verification: Verification of business registration documents with the relevant registration authority (e.g., DMCC or the applicable US state registry).
  • Stripe Validation: Confirmation that the Stripe account is active, verified, and not subject to prior sanctions.

3. Merchant Vetting

We apply equal or greater scrutiny to the high-volume e-commerce Merchants we bring to the platform. We verify:

  • Legitimacy of the products and services sold.
  • Historical processing volumes and chargeback ratios.
  • Screening against applicable sanctions lists, including United Nations, UAE, and US OFAC lists, as relevant to the relationship or transaction.

4. Ongoing Monitoring

Compliance does not end at onboarding. Our team utilizes advanced monitoring tools to continuously supervise transaction velocity and patterns.

  • If unusual activity is detected, we may temporarily suspend payouts while we conduct an investigation.
  • We reserve the right to immediately terminate any partnership and notify the necessary authorities if we suspect illicit activity.

5. Reporting Obligations

Suspected money laundering, terrorist financing, or sanctions violations are assessed under the laws applicable to the relevant entity and activity. Where a reporting obligation applies, reports are made to the competent authority through the required channel. In the UAE, this may include reporting to the UAE Financial Intelligence Unit through goAML; in the United States, this may include reporting to FinCEN under applicable Bank Secrecy Act requirements. Reporting requirements depend on the activity and regulatory status; a DMCC registration or US office alone does not establish a particular reporting obligation.