Anti-Money Laundering (AML) Policy

Last Updated: September 9, 2025

Orbit Labs LLC (“Orbit”) is a decentralized, non-custodial software provider enabling users to interact with smart contracts deployed on the Hedera distributed ledger. While Orbit does not provide custodial services, hold user funds, or facilitate fiat-to-crypto or crypto-to-fiat transactions, we are committed to supporting global efforts to combat money laundering, terrorist financing, and other illicit activity.

In alignment with applicable legal standards and best practices—including U.S. Money Transmitter License (MTL) considerations, EU Markets in Crypto-Assets Regulation (MiCA), and Financial Action Task Force (FATF) guidance—Orbit maintains a proactive, risk-based approach to address potential abuse of its services.

Orbit Labs LLC maintains and operates the frontend interface at Orbit-hbar.io, which enables interaction with the Orbit smart contracts deployed on the Hedera network. While smart contracts are public and accessible without our interface, this policy governs use of the frontend and Orbit-owned infrastructure.

Non-Custodial and Decentralized Nature

Orbit is a decentralized protocol interface and does not:

• Hold or control user assets.

• Interact with decrypted private keys or personal credentials.

• Serve as a financial intermediary or counterparty to trades.

• Provide user matching, brokerage, or custodial services.

• Facilitate fiat transactions or operate a fiat on/off ramp.

All user transactions are self-directed and executed on-chain via smart contracts, ensuring that users maintain full custody and responsibility over their digital assets at all times.

Orbit personnel cannot access, transfer, freeze, or modify user funds or smart contract balances at any time.

This AML Policy is provided as a matter of good practice and regulatory alignment. It does not imply that Orbit is a financial institution, money services business, or otherwise subject to licensing as a custodian or money transmitter.

Jurisdictional Restrictions and Geo-Blocking

Orbit restricts access to the Platform from:

• Jurisdictions subject to U.S. OFAC sanctions or other applicable international restrictions.

Orbit reserves the right to update or modify these restrictions based on regulatory developments and compliance requirements, and may implement technical measures such as IP-based geo-blocking to enforce them.

Wallet Monitoring and Transaction Review

Orbit does not currently collect personally identifiable information (PII) or perform Know Your Customer (KYC) procedures. However, to mitigate exposure to unlawful activity, Orbit reserves the right to limit or block access to wallets or smart contract interactions associated with:

• Addresses flagged by U.S. OFAC or similar sanctions enforcement authorities.

• Wallets linked to known exploits, malware campaigns, or illicit activity. Orbit may also restrict access to addresses associated with mixing or obfuscation services where required by law or regulatory guidance.

• Distributed ledger addresses flagged by industry-recognized security firms or open-source intelligence (OSINT) providers.

Future Integration of Screening Tools

Orbit does not presently conduct automated real-time wallet or transaction screening. However, we reserve the right to implement distributed ledger analytics and monitoring solutions in the future to support our risk management strategy and regulatory alignment. Orbit may, at its discretion, implement blockchain analytics or sanctions-screening tools to support compliance. Any such integrations will be disclosed through Orbit’s official documentation.

AML Risk Mitigation Framework

Orbit applies a multi-pronged approach to reduce the risk of illicit activity:

• Geo-Blocking to restrict access from high-risk jurisdictions.

• Wallet Screening (future use) to detect and limit activity from sanctioned or compromised addresses.

• No Custody / No Fiat services to minimize misuse for traditional laundering vectors.

• Cooperation with Legal Authorities in accordance with applicable law, including responding to lawful court orders or regulatory inquiries.

• Public Ledger Transparency—all transactions are visible on the Hedera network and verifiable on-chain.

• Transaction Finality—All user interactions on the Platform are final and irreversible once executed on the Hedera network. Orbit does not control, reverse, or modify smart contract transactions under any circumstances. Users are solely responsible for confirming transaction details prior to approval.

Policy Changes and User Responsibilities

Orbit monitors global regulatory developments and may revise this AML policy at any time to maintain alignment with emerging standards. Policy updates may be published in the Terms of Use, Privacy Policy, and through Orbit’s official documentation channels, including GitBook or the main website.

By accessing or using the Platform, you represent and warrant that:

• You are not accessing the Platform from a prohibited jurisdiction.

• You are not using the Platform to facilitate illegal activity.

• You understand and accept that Orbit may limit access to users or addresses that raise legal, compliance, or reputational risk concerns.

For AML-related questions, please contact: [e-mail]