KEYBINO
Quantara Solutions Ltd
Anti-Money Laundering and Counter-Terrorist Financing Statement
Public Policy Statement • United Kingdom
Effective Date: 1 April 2026
This document is the public-facing AML/CTF Policy Statement of Quantara Solutions Ltd, trading as Keybino (“Company”), registered in England and Wales (No. 17073809), with registered address at 20 Wenlock Road, London, N1 7GU, England, United Kingdom.
This Statement sets out the Company’s overarching commitment to compliance with applicable AML/CTF legislation. The Company’s detailed internal compliance procedures and controls are maintained separately and are not disclosed publicly.
1. Regulatory Framework
The Company operates in compliance with:
- The Proceeds of Crime Act 2002 (as amended) (“POCA”);
- The Terrorism Act 2000 (as amended);
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) (“MLR 2017”);
- The Counter Terrorism and Security Act 2015;
- The Sanctions and Anti-Money Laundering Act 2018;
- Sanctions regimes administered by HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) and the UN Security Council;
- Guidance issued by HMRC and Financial Action Task Force (“FATF”) Recommendations, and HMRC AML/CTF guidance for relevant business sectors.
Regulatory perimeter: The Company continuously monitors whether its business activities require registration with HMRC or another supervisory body for AML purposes under the MLR 2017. Where such registration becomes required, the Company will register promptly and maintain that registration in good standing.
2. Business Risk Profile
The Company is developing and will maintain a documented Business Risk Assessment (BRA) in accordance with Regulation 18 MLR 2017. The BRA identifies and assesses money laundering and terrorist financing risks associated with the Company’s business model, products, customers, and geographic exposure. Key risk factors include:
- the non-tangible and instantly deliverable nature of Digital Products;
- the potential for cross-border transactions and anonymous purchasing activity;
- the risk of Digital Products being used for value transfer or resale in secondary markets;
- the risk of compromised or stolen payment methods being used.
The Company applies controls proportionate to identified risks. The BRA will be reviewed at least annually and updated following any material change to the Company’s business or applicable regulatory requirements.
3. Compliance Commitment
3.1. Customer Due Diligence (CDD)
The Company applies risk-based CDD measures to verify the identity of customers and understand the nature of the business relationship. CDD is applied at onboarding, at the point of transaction where risk indicators are present, and on an ongoing basis.
3.2. Enhanced Due Diligence (EDD)
Where a customer or transaction presents elevated risk, the Company applies EDD proportionate to that risk. EDD may include additional identity documentation, source of funds verification, and enhanced monitoring.
3.3. Know Your Customer (KYC)
The Company may require Users to complete KYC verification at any stage. Details of the documents required are set out in the KYC Policy available at https://keybino.com.
3.4. Transaction Monitoring
The Company employs automated and manual controls to monitor transactions for indicators of suspicious activity, including unusual purchasing patterns, inconsistent payment methods, and structuring behaviour.
3.5. Sanctions Screening
Customers and transactions are screened against applicable sanctions lists, including those maintained by OFSI and the UN Security Council. Where a transaction has a demonstrable US nexus, US OFAC sanctions lists are also applied. Any match or potential match results in immediate Account restriction and compliance review.
3.6. Politically Exposed Persons (PEPs)
The Company applies enhanced scrutiny to individuals identified as PEPs, or as their close associates or family members, in accordance with the MLR 2017.
4. Suspicious Activity Reporting
Where the Company identifies or reasonably suspects that a transaction or activity involves proceeds of crime, terrorist financing, or sanctions evasion, it is required under POCA 2002 to submit a Suspicious Activity Report (“SAR”) to the National Crime Agency (“NCA”).
The Company operates a strict tipping-off prohibition: it will not disclose to any User or third party that a SAR has been, or may be, filed (s.333A POCA 2002). The Company may suspend or decline a transaction without providing a reason where a SAR is being considered.
5. Record Keeping
The Company retains KYC documentation and transaction records for a minimum of five (5) years from the end of the relevant business relationship or the date of the relevant transaction, in accordance with Regulation 40 MLR 2017. Records are stored securely and made available to competent authorities upon lawful request.
6. Staff Training and Governance
Relevant personnel receive training on AML/CTF obligations, internal policies, and red flag indicators. The Company has designated a senior individual responsible for overseeing AML/CTF compliance and for ensuring that Suspicious Activity Reports are filed with the NCA where required. Contact details of the designated compliance officer are maintained in the Company’s internal compliance records.
7. Consequences for Users
Users who engage in conduct that violates applicable AML/CTF law, or who provide false or misleading information in connection with compliance checks, will have their Accounts suspended or terminated without notice. The Company will report such conduct to the relevant authorities and cooperate fully with any resulting investigation.
8. Policy Review
This Statement and the Company’s internal AML/CTF procedures are reviewed at least annually, and following any material change to applicable legislation, regulatory guidance, or the Company’s business model.
Contact Information
| Legal Name | Quantara Solutions Ltd |
| Trading Name | Keybino |
| Company Number | 17073809 |
| Registered Address | 20 Wenlock Road, London, N1 7GU, England, United Kingdom |
| Website | https://keybino.com |
| General Support | [email protected] |
| Compliance | [email protected] |
| Privacy | [email protected] |
Last Updated: 1 April 2026