Anti-Fraud, AML, and Compliance Policy

Halcyon Trader Funding LLC ("HTF") is firmly committed to maintaining a secure, compliant, transparent, and lawful operating environment and strictly prohibits the use of its platform, services, accounts, subscription products, prediction market products, simulated market products, evaluation services, software, technology, systems, or infrastructure for any unlawful, abusive, manipulative, deceptive, fraudulent, money laundering, terrorist financing, sanctions evasion, market manipulation, payment fraud, identity fraud, or other prohibited activities. HTF actively monitors all platform activity, payment activity, subscription activity, account activity, transactional behavior, device information, network information, login history, geolocation data, IP addresses, browser fingerprints, usage patterns, trading patterns, prediction market activity, communications, and related user activity for the purposes of fraud prevention, anti-money laundering compliance, sanctions screening, identity verification, regulatory compliance, risk management, operational integrity, security enforcement, payment verification, dispute prevention, platform stability, and protection of the company, its users, vendors, processors, partners, regulators, and the general public. By accessing, purchasing, subscribing to, registering for, funding, or otherwise using any products or services offered by HTF, the user expressly consents to such monitoring, review, investigation, storage, analysis, and disclosure of information as deemed necessary by HTF in its sole discretion.

HTF reserves the unrestricted right at any time and without notice to suspend, freeze, restrict, terminate, investigate, deny, withhold, reverse, delay, cancel, void, liquidate, archive, remove, or permanently ban any account, subscription, payout, balance, simulated balance, user profile, transaction, payment, withdrawal request, promotional credit, service access, or platform activity for any compliance, operational, legal, fraud prevention, regulatory, business, reputational, technical, payment processing, AML, sanctions, security, or risk management reason as determined solely by HTF. No user has a guaranteed right to platform access, subscription continuation, account retention, payout eligibility, account reinstatement, or continued use of any services provided by HTF. HTF reserves the right to refuse service to any individual, entity, device, household, jurisdiction, region, payment method, business, organization, or user category at any time and for any reason or no reason whatsoever. Prediction market services, subscription products, simulated accounts, evaluation products, and related services may not be available in all jurisdictions, and the user is solely responsible for determining whether access to or use of HTF services is legal within their jurisdiction. Users located in restricted, prohibited, sanctioned, embargoed, or otherwise unauthorized jurisdictions are strictly prohibited from accessing or using HTF services. The use of VPNs, proxies, TOR networks, remote desktop software, identity masking tools, IP manipulation services, location spoofing tools, emulator environments, synthetic identities, fake credentials, stolen payment methods, false documentation, or any technology designed to conceal, alter, manipulate, disguise, or misrepresent a user's true identity, jurisdiction, location, device, or activity is strictly prohibited and may result in immediate account termination, forfeiture of all balances or profits, permanent bans, reporting to authorities, and potential civil or criminal action.

HTF conducts customer due diligence ("CDD"), enhanced due diligence ("EDD"), sanctions screening, identity verification, fraud analysis, transaction monitoring, behavioral analysis, and risk scoring procedures on all users and reserves the right to request additional documentation at any time including but not limited to government issued identification, proof of address, banking documentation, source of funds documentation, source of wealth documentation, tax documentation, business registration records, selfies, video verification, live verification checks, payment verification documentation, utility bills, and any other documentation deemed necessary for compliance or risk management purposes. Failure or refusal to provide requested information within the timeframe determined by HTF may result in immediate suspension, withholding of payouts, denial of services, closure of accounts, forfeiture of balances, permanent bans, or reporting to regulators or law enforcement authorities.

HTF complies with all applicable anti-money laundering ("AML"), counter-terrorist financing ("CTF"), sanctions, fraud prevention, financial crime, and compliance laws and regulations including but not limited to the Bank Secrecy Act ("BSA"), the USA PATRIOT Act, OFAC sanctions requirements, FinCEN regulations, FATF Recommendations, international sanctions programs, anti-fraud laws, and any applicable federal, state, local, or international compliance obligations. HTF reserves the right to cooperate fully with law enforcement agencies, regulatory authorities, courts, payment processors, banks, exchanges, analytics providers, fraud prevention vendors, identity verification vendors, government agencies, and financial intelligence units and may disclose any user information, activity, documentation, communications, records, account history, payment records, IP logs, device data, transactional data, or related information where deemed necessary or appropriate by HTF for legal, regulatory, investigative, compliance, fraud prevention, operational, or security purposes. HTF may file Suspicious Activity Reports ("SARs") or equivalent reports with relevant authorities without notice to the user whenever activity is deemed suspicious, unusual, inconsistent, high-risk, fraudulent, evasive, manipulative, abusive, or otherwise concerning in HTF's sole discretion.

HTF maintains a strict zero tolerance policy toward fraud, market abuse, collusion, coordinated activity, bonus abuse, multi-accounting, referral abuse, payment fraud, chargeback abuse, synthetic identity usage, account sharing, account sales, account rentals, account transfers, spoofing, wash trading, manipulation, exploitative trading behavior, unauthorized automation, API abuse, exploit abuse, data scraping, platform attacks, circumvention of limits or restrictions, or any conduct deemed harmful to HTF, its users, vendors, regulators, processors, or partners. HTF reserves the right to retroactively void, reverse, remove, cancel, deny, confiscate, or invalidate any trades, contracts, predictions, payouts, credits, promotions, balances, winnings, simulated profits, or account activity believed to be associated with abusive, manipulative, coordinated, suspicious, fraudulent, unlawful, exploitative, or prohibited conduct. HTF further reserves the right to recover losses, damages, processor fees, penalties, legal expenses, investigative costs, administrative costs, compliance costs, and any related expenses arising from user misconduct through offsets, withholding of balances, collections activity, arbitration, civil litigation, or any other lawful means available.

Users acknowledge and agree that HTF services may be interrupted, delayed, inaccurate, unavailable, suspended, or inaccessible at times due to maintenance, software issues, hardware failures, market disruptions, exchange issues, third-party outages, cyberattacks, internet failures, regulatory actions, force majeure events, data delays, pricing discrepancies, compliance reviews, fraud investigations, payment processor issues, or other events beyond HTF's control, and HTF shall bear no liability whatsoever for any losses, damages, missed opportunities, denied payouts, interrupted subscriptions, or inability to access services resulting therefrom. HTF does not provide investment advice, financial advice, securities advice, brokerage services, commodity trading advice, legal advice, tax advice, fiduciary services, banking services, or guarantees of profitability, performance, payouts, success, or earnings. All services are provided strictly on an "as is" and "as available" basis without warranties of any kind, express or implied. Users assume all risk associated with use of HTF services and agree that HTF shall not be liable for any direct, indirect, incidental, consequential, exemplary, punitive, or special damages arising from or related to use of the services.

HTF would also like to alert users to the risk of fraudulent impersonators, spoofed communications, cloned websites, fake domains, phishing attacks, social engineering scams, fraudulent social media accounts, fake representatives, and unauthorized third-party services claiming affiliation with HTF. HTF's official domains may include but are not limited to domains owned or operated by Halcyon Trader Funding LLC, and users are solely responsible for verifying the legitimacy and authenticity of any website, communication, email, payment request, social media profile, or service claiming association with HTF before transmitting funds, credentials, personal information, payment details, or identification documents. HTF bears no responsibility or liability whatsoever for losses, damages, identity theft, payment fraud, unauthorized access, stolen funds, or compromised information resulting from interactions with third-party impersonators, fraudulent websites, cloned services, spoofed domains, phishing campaigns, or unauthorized entities falsely claiming affiliation with HTF.

By using HTF services, the user acknowledges and agrees that they have fully read, understood, and accepted this policy in its entirety and agree that this policy forms a legally binding part of HTF's Terms of Service and all related agreements enforceable to the maximum extent permitted by law.