AML Policy

Effective date: 10 May 2026

This Anti-Money-Laundering (“AML”) and Counter-Terrorist-Financing (“CTF”) Policy sets out the framework that NOVENTRAX LTD (company number 17202611), trading as “ArtPixelVault” (“we”, “us”, “our”), applies to its operations on https://artpixelvault.com (the “Site”).

The Site sells digital files (PBR materials, HDRI environments, 3D models and bundle packs). Payments are processed by PCI-DSS-certified third-party processors. We do not handle cash, virtual-asset transfers, or peer-to-peer payments on our own servers.

1. Regulatory framework

We comply with applicable UK and EU legislation, including:

• the Proceeds of Crime Act 2002;
• the Terrorism Act 2000;
• the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended);
• UK and EU sanctions regimes, including those administered by HM Treasury’s Office of Financial Sanctions Implementation (OFSI), the EU Council and the UN Security Council;
• relevant guidance from the Financial Action Task Force (FATF).

2. Risk-based approach

We apply controls proportionate to the risk profile of the Site. Because we sell low-to-mid value digital assets via card-payment processors, the residual risk is low. Controls are concentrated on:

• screening counterparties;
• monitoring transaction patterns;
• restricting access from sanctioned jurisdictions;
• record retention.

We review this risk assessment at least annually, or sooner if the business model changes (for example, on introduction of higher-value tiers, B2B invoicing or alternative payment methods).

3. Know-Your-Customer (KYC)

For low-to-mid value, card-funded purchases we rely primarily on the KYC procedures of our regulated payment processors. In addition we monitor:

• the email address and account history of the buyer;
• the IP address and country of access;
• the billing country reported by the payment processor;
• BIN-level information about the card or method used;
• behavioural signals that indicate automation or fraud.

For higher-value, B2B or recurring engagements we may, at our discretion, request additional documentary KYC (proof of identity, proof of address, company registration extract, ultimate-beneficial-owner declaration). We may decline to onboard or continue any customer who refuses to provide reasonably requested information.

4. Restricted jurisdictions

We do not sell to, or enter into business relationships with, individuals or entities located in or controlled from jurisdictions subject to comprehensive UK, EU, UN or US sanctions, including (without limitation):

• Crimea, the so-called Donetsk and Luhansk People’s Republics;
• Cuba;
• Iran;
• North Korea (DPRK);
• Syria;
• the Russian Federation;
• Belarus.

We also screen against current consolidated sanctions lists. Where a payment is identified as originating from such a jurisdiction or matching a sanctioned party, we will refuse the transaction and may freeze related accounts pending investigation.

5. Transaction monitoring — red flags

The following patterns are treated as red flags and may trigger enhanced review or refusal:

• multiple failed payment attempts followed by a successful one with a different card;
• unusual concentration of purchases from anonymising or high-risk infrastructure (TOR exit nodes, datacentre IP ranges, residential proxies known for fraud);
• accounts that exhibit credential-stuffing or scraping behaviour;
• inconsistencies between the billing country, IP geolocation, and account profile;
• high-volume rapid purchases inconsistent with typical 3D-asset-marketplace usage;
• requests to split a single purchase into structured smaller payments;
• requests to receive refunds to a different account or in a different currency.

6. Suspicious Activity Reporting (SAR)

Where we identify activity reasonably suspected to involve money laundering, terrorist financing or sanctions breaches, we will file a Suspicious Activity Report with the UK National Crime Agency and, where required, with other relevant competent authorities. We will cooperate with lawful information requests from law-enforcement bodies.

We will not “tip off” the subject of a report in a way that prejudices an investigation, in line with section 333A of the Proceeds of Crime Act 2002.

7. Record retention

We retain customer and transaction records, KYC information (where collected), and SAR-related materials for a minimum of five years after the end of the business relationship or completion of the relevant transaction, in line with regulation 40 of the Money Laundering Regulations 2017.

8. Internal responsibilities

The director of NOVENTRAX LTD is the nominated officer responsible for AML/CTF compliance and acts as the point of contact for SAR submissions and law-enforcement requests. The Money Laundering Reporting Officer can be reached at info@artpixelvault.com. Any change in nominated officer will be recorded internally.

9. User obligations

By using the Site you confirm that:

• the funds used to pay for any Content are derived from lawful sources;
• you are not subject to UK, EU, UN or US sanctions, and you are not acting on behalf of a sanctioned person or entity;
• you are not located in, organised under, or controlled from a restricted jurisdiction listed above;
• you will not use the Content to support unlawful activity.

Breach of any of these confirmations may result in immediate account suspension and report to the relevant authorities.

10. Contact

NOVENTRAX LTD
Studio No. 14, 138 Marylebone Road, London, England, NW1 5PH
Company number: 17202611
info@artpixelvault.com · +44 7458 164988