Anti-Money Laundering (AML) and Counter Terrorism Financing (CFT) Policy

Effective Date: 20th Oct 2025

Entity: Effortless Labs PTE. Ltd. (UEN 202424642E)

Registered Office: 165B Telok Ayer Street, Singapore 068617

1. Purpose and Commitment

Effortless Labs PTE. Ltd. (“Effortless Labs”, “Igris”, “we”, “our”) is firmly committed to preventing money laundering, terrorist financing, and any activity that facilitates or supports such crimes.

Although Igris.bot operates as a non-custodial, interface-only platform that does not hold user funds or private keys, Effortless Labs voluntarily upholds AML/CFT standards consistent with the Monetary Authority of Singapore (MAS) Notice 626, the Financial Action Task Force (FATF) recommendations, and global best practices.

2. Scope

This Policy applies to all:

  • Users accessing or interacting with the Igris platform, APIs, or SDKs;
  • Employees, contractors, and service providers of Effortless Labs;
  • Partners and third-party vendors engaged in liquidity, compliance, or data-service integration.

3. Nature of the Platform

Igris is a non-custodial smart-contract interface enabling multi-chain swaps and settlements.

Users connect self-hosted wallets; Igris never controls, stores, or transfers funds on behalf of users.

Because of this model, Effortless Labs is not a financial institution and does not perform traditional KYC onboarding.

However, we apply risk-based AML/CFT controls to detect and deter illicit activity that could exploit our infrastructure.

4. Policy Objectives

Effortless Labs implements AML/CFT measures to:

  1. Detect and prevent use of the Igris platform for money laundering or terrorist financing;
  2. Comply with relevant Singaporean and international regulations;
  3. Promote transparency and integrity across the DeFi ecosystem;
  4. Cooperate with law-enforcement agencies when legally required.

5. Risk-Based Approach

We assess risks across the following vectors:

  • Geographic Risk – Monitoring activity from sanctioned or high-risk jurisdictions as defined by MAS and FATF.
  • Transaction Risk – Evaluating volume, frequency, and on-chain mixing patterns.
  • Counterparty Risk – Screening counterparties and liquidity sources through blockchain analytics.
  • Technology Risk – Continuous evaluation of smart-contract interactions and API access.

6. AML Controls and Procedures

6.1 Blockchain Screening

We employ on-chain analytics tools (e.g., Chainalysis, TRM Labs, Elliptic API) to detect transactions associated with:

  • Sanctioned entities or addresses;
  • Dark-web or mixer activity;
  • Fraudulent, hacked, or stolen funds.

Suspicious wallet addresses are flagged and restricted from interacting with our services.

6.2 Sanctions and Watchlists

We maintain updated screening lists including:

  • MAS Designated Individuals and Entities;
  • United Nations (UN) Sanctions;
  • Office of Foreign Assets Control (OFAC);
  • European Union (EU) and UK HMT lists.

Access from sanctioned jurisdictions is blocked where technically possible.

6.3 Transaction Monitoring

Automated systems analyze transaction patterns for:

  • Rapid, repetitive small-value transfers;
  • Cross-chain swaps inconsistent with known DeFi behavior;
  • Unusual routing through multiple intermediaries.

Suspicious patterns trigger internal review.

6.4 Reporting Suspicious Activity

If Effortless Labs identifies suspicious transactions or user activity, it may:

  • Freeze or restrict related API endpoints;
  • Record and securely retain relevant logs;
  • File a Suspicious Transaction Report (STR) with the Suspicious Transaction Reporting Office (STRO) of Singapore.

6.5 Record Keeping

Transaction and analytics data are retained for five (5) years in accordance with MAS Notice 626 §4.

Records are encrypted and stored securely, accessible only to authorized personnel.

6.6 Employee Awareness

All employees undergo annual AML/CFT training covering:

  • Recognizing red-flag behaviors;
  • Proper reporting procedures;
  • Data-handling and privacy obligations.

7. Prohibited Jurisdictions

Users are prohibited from accessing or using Igris from jurisdictions subject to:

  • Comprehensive OFAC, UN, or MAS sanctions;
  • FATF-identified “High-Risk and Non-Cooperative Jurisdictions.”

Currently, this includes (subject to updates): North Korea, Iran, Syria, Cuba, Sudan, Crimea, Donetsk, and Luhansk regions, among others.

8. Cooperation with Authorities

Effortless Labs cooperates fully with lawful requests from:

  • Monetary Authority of Singapore (MAS);
  • Suspicious Transaction Reporting Office (STRO);
  • Other competent authorities or courts.

All disclosures are made in accordance with applicable privacy and data-protection laws.

9. Independent Audit and Review

This AML/CFT framework is reviewed annually by internal compliance or qualified external auditors to ensure:

  • Policy adequacy and operational effectiveness;
  • Alignment with evolving regulatory standards;
  • Proper documentation of STRs, risk assessments, and staff training.

10. Governance and Accountability

  • AML Compliance Officer (MLRO)
  • Email: legal@igris.bot
  • Responsibilities: Implementing AML procedures, monitoring alerts, reporting STRs, and coordinating audits.

The MLRO reports directly to the company’s Directors.

11. Non-Compliance Consequences

Any employee or partner found violating AML obligations may face:

  • Disciplinary action (up to termination);
  • Civil or criminal penalties under applicable laws;
  • Blacklisting from Effortless Labs’ partner network.

12. Policy Review and Updates

Effortless Labs reviews this Policy at least annually or upon regulatory change.

Updated versions are posted at https://www.igris.bot/aml with the revision date indicated at the top.

13. Contact Information

Effortless Labs PTE. Ltd.

Email: legal@igris.bot

Address: 165B Telok Ayer Street, Singapore 068617

Statement of Assurance

Effortless Labs strives to maintain a transparent, secure, and responsible ecosystem.

While Igris is non-custodial and user-controlled, we take proactive measures to ensure that our infrastructure cannot be misused for illicit activities.

Compliance is integral to our mission to build trust in the future of decentralized finance.