AIO SOLUTIONS AG
Effective Date: 1st of November 2025
Geneva, Switzerland
- Introduction
AIO SOLUTIONS AG is firmly committed to combating money laundering, the financing of terrorism, and the circumvention of international sanctions. This commitment is embedded in all our operations and aligned with Swiss and international legal frameworks. We adhere strictly to the Federal Act on Combating Money Laundering and Terrorist Financing (AMLA, RS 955.0), the FINMA Anti-Money Laundering Ordinance (AMLO-FINMA), and the directives issued by our Self-Regulatory Organisation (SO-FIT), which is officially recognised by the Swiss Financial Market Supervisory Authority (FINMA). In addition, we follow the applicable international standards established by the Financial Action Task Force (FATF). - Legal Status
AIO SOLUTIONS AG is a Swiss-registered company, incorporated under the number CHE-492.759.632 and headquartered in Geneva. As a financial intermediary within the meaning of Article 2, paragraph 3 of the AMLA, Alea is an active member of SO-FIT. We operate as a Payment Service Provider (PSP) and, in some cases, as a Virtual Asset Service Provider (VASP), under the relevant Swiss regulatory perimeter. Our internal AML framework is overseen by a designated AML Compliance Officer, who is responsible for ensuring adherence to legal, operational and ethical standards. We maintain a compliance contact address compliance@aio.net. - Customer Due Diligence
Before establishing a business relationship, we perform comprehensive Know Your Customer (KYC) checks. These include the identification and verification of all natural and legal persons, the identification of beneficial owners and controlling persons, and the collection of supporting documentation to verify the purpose and intended nature of the relationship. Depending on the service, we may use digital identification tools such as video identification, NFC chip passport readers, or bank account verification. The declarations required under Swiss AML law, such as Form A or Form K, are also collected when applicable. - Risk Classification and Screening
Each client is assigned a risk level based on factors such as their jurisdiction, corporate structure, exposure to political influence, and the nature and expected volume of their activity. Clients deemed high-risk are subject to enhanced due diligence measures. We conduct continuous screening against international sanctions lists, including those issued by SECO (Switzerland), the European Union, the United Nations, and the United States (OFAC SDN list). Politically Exposed Persons (PEPs) and adverse media screening are also conducted using reliable global databases. Any matches are escalated immediately to the AML Compliance Officer for review and appropriate action. - Transaction Monitoring
We continuously monitor client activity, including fiat and digital asset transactions. This includes real-time tracking through both automated systems and manual oversight. Alerts are generated in the event of large, rapid, or otherwise unusual transaction behaviour. Transactions involving structuring, layering, or obfuscation strategies are reviewed by compliance. When dealing with digital assets, blockchain analytics tools are used to detect connections to mixers, sanctioned wallets, ransomware addresses, or darknet services. Where applicable, we comply with the FATF Travel Rule by sharing originator and beneficiary data in inter-VASP transfers. - Suspicious Activity and Reporting
Where we suspect or become aware that funds may be related to a criminal offence, terrorist financing, or involve incomplete or false client identification, we fulfil our obligations under Article 9 of the AMLA. This may result in the submission of a suspicious activity report to the Money Laundering Reporting Office Switzerland (MROS). In such cases, the account may be frozen and the client will not be notified, as the law prohibits “tipping off” in such circumstances. We cooperate fully with FINMA, MROS, SO-FIT, and other competent Swiss authorities when legally obligated to do so. - Business Refusals and Termination
Alea reserves the right to reject or terminate a business relationship without notice if a client fails to provide adequate identification, is associated with a high-risk or non-cooperative jurisdiction, or engages in business activities that are incompatible with our risk appetite. These include but are not limited to unregulated gambling operations, anonymous payment services, or entities connected to sanctioned regimes or embargoed territories. Clients linked to shell banks, mixer services, or high-risk financial platforms are also excluded from our services. - Staff Training and Governance
All relevant staff are trained regularly on AML and CTF procedures. Training is mandatory and conducted at least once per year, covering evolving typologies, regulatory developments, and operational compliance procedures. Alea follows a three-lines-of-defence model for compliance: first-line business units ensure initial client checks, the second line consists of the compliance function which monitors and advises, and the third line comprises audit and external reviews. The AML Compliance Officer reports annually to the Board of Directors, outlining major compliance events, risk evolution, and SAR activity. - Recordkeeping and Data Security
We retain all client identification data, transaction history, and compliance documentation for a minimum of ten years, in accordance with Article 7 of AMLA and Article 22 of AMLO-FINMA. These records are stored securely in encrypted databases located in Switzerland or EEA jurisdictions with adequate data protection legislation. Access is restricted to authorised personnel only and follows role-based access control principles. - Third Parties and Outsourcing
Where onboarding, screening, or infrastructure is outsourced to third parties, Alea ensures that these partners are compliant with Swiss AML standards. All service providers are vetted, contractually bound to data protection and AML clauses, and monitored for performance. Ultimate legal responsibility for compliance remains with Alea at all times. No sub-outsourcing is permitted unless explicitly approved in writing. - Contact and Reporting
If you have concerns about suspicious activity, potential breaches of compliance, or would like to report an incident, you can contact compliance@aio.net our compliance department confidentially via email. We handle all reports with discretion and in full accordance with Swiss legal protections for whistleblowers and reporting parties. - Final Notes
AIO SOLUTIONS AG continuously reviews and updates its AML/CTF framework to reflect changes in law, FATF guidance, or internal risk assessments. Our goal is to offer best-in-class financial technology services while upholding the highest standards of integrity, transparency, and regulatory compliance.