AML and Counter-Terrorist-Financing Policy
Last updated 27 August 2026
1. Our Commitment
360 Logistics Limited operates Zelencio with a zero-tolerance approach to money laundering, terrorist financing and sanctions evasion. This policy explains what we do about it and what we require from you.
2. Legal Framework
As a global platform, we align our programme with the international standards of the Financial Action Task Force (FATF), including the Travel Rule for virtual asset transfers, and with the anti-money-laundering laws of the countries we serve — such as the EU Anti-Money Laundering Directives and MiCA transfer rules, the UK Money Laundering Regulations, the US Bank Secrecy Act and Nigeria’s Money Laundering (Prevention and Prohibition) Act.
3. Know Your Customer
Every user must complete identity verification before withdrawing, trading peer-to-peer or accessing higher limits. We collect a government-issued document, a live face capture and your date of birth, and we screen every user against sanctions lists, politically-exposed-person lists and adverse media.
4. Enhanced Due Diligence
Where risk is higher — large volumes, high-risk jurisdictions, politically exposed persons, or unusual funding patterns — we require additional evidence, including proof of address and proof of source of funds. Until it is provided, the relevant limits stay closed.
5. Transaction Monitoring
Automated systems monitor activity for structuring, rapid deposit-and-withdraw cycling, mule networks, self-referral and multi-account patterns, mismatched payment names in P2P trades, and transfers involving addresses associated with theft, ransomware, darknet markets or sanctioned entities.
6. Blockchain Analytics
Deposit and withdrawal addresses are screened against known illicit-activity databases. Funds traced to a reported theft or a sanctioned address may be frozen and reported. Do not deposit funds from a source you cannot account for.
7. Reporting
Where we identify suspicious activity we file the reports required by law. In most cases the law prohibits us from telling you that a report has been made. This is a legal restriction on us, not evasion.
8. Record Keeping
Identity records and transaction history are retained for at least five years after account closure, as required by law.
9. Prohibited
- Using another person’s identity or documents, or opening an account for someone else without disclosure.
- Acting as a money mule, or accepting funds from strangers in exchange for a fee.
- Structuring transactions to stay under a reporting threshold.
- Using Zelencio to move the proceeds of crime, or to fund terrorism or a sanctioned party.
10. Consequences
Breach results in account freezing, closure and referral to the appropriate authority, with all evidence preserved.
11. Governance
A designated compliance officer owns this programme. Staff receive AML training and the programme is reviewed regularly. Report a concern to security@zelencio.com.