Risk, Sanctions & AML Policy

Last Updated: August 12, 2026
Effective Date: April 1, 2026

SpeedyTurtle Labs, LLC, a Florida limited liability company (“SpeedyTurtle,” “Company,” “we,” “us,” or “our”), operates a non-custodial software platform that provides user-directed tools for interacting with public blockchains and third-party protocols.

This Policy supplements and is incorporated by reference into the SpeedyTurtle Terms of Service. The Privacy Policy describes how SpeedyTurtle processes personal information, including public blockchain and Wallet-related information.

1. NATURE OF THE PLATFORM

SpeedyTurtle provides software interfaces, analytics, alerts, and automation tools. Users choose the Wallets, assets, strategies, settings, and instructions they use with the Services.

SpeedyTurtle does not:

• take beneficial ownership of user Digital Assets;
• use Wallet credentials or transaction authority for its own account;
• act as a broker, exchange, payment processor, or investment adviser;
• reverse, cancel, or modify transactions after submission to a blockchain network.

Wallet creation, recovery, key management, and signing may be provided through a third-party Key Infrastructure Provider. Transactions are processed under user-authorized instructions, including manual requests and automated strategy rules a user activates.

2. PUBLIC BLOCKCHAIN AND WALLET DATA

Public blockchains expose addresses, balances, asset holdings, and transaction histories. To provide features described in the documentation, SpeedyTurtle may process public blockchain data associated with Wallets a user creates, connects, manages, or chooses to track. This processing may include:

• retrieving Wallet balances and transaction status;
• detecting activity from tracked Wallets;
• generating copy-trade signals, alerts, positions, and activity records;
• analyzing public transactions or Wallet flows for product functionality, platform security, abuse prevention, and legal compliance.

Processing or analyzing public blockchain data does not give SpeedyTurtle custody of Digital Assets or the ability to freeze, reverse, or seize an on-chain transaction. Public blockchain information remains visible independently of SpeedyTurtle.

3. THIRD-PARTY KEY INFRASTRUCTURE

SpeedyTurtle uses a third-party Key Infrastructure Provider, such as Turnkey, to support Wallet creation, recovery, cryptographic key management, and transaction signing.

The provider processes Wallet operations under user-authorized instructions. SpeedyTurtle does not have authority to use Wallet credentials or signing material for its own account or outside a user’s manual requests or activated strategy rules.

Third-party infrastructure can experience outages, delays, security incidents, or other failures. Additional risks are described in the Risk Disclosure.

4. LEGAL STATUS AND NO ROUTINE KYC ONBOARDING

SpeedyTurtle provides non-custodial software tools and does not represent that it operates as a bank, broker, exchange, custodian, or money transmitter. This description does not override Applicable Law or determine how a regulator or court may classify a particular activity.

SpeedyTurtle does not conduct routine Know Your Customer (KYC), Anti-Money Laundering (AML), or customer-due-diligence checks as a condition of ordinary account creation or access to the Services. SpeedyTurtle may request information, restrict access, or take other measures when reasonably necessary to comply with Applicable Law, respond to a lawful request, or address suspected fraud or abuse.

Nothing in this Policy limits any obligation that Applicable Law imposes on SpeedyTurtle.

5. SANCTIONS AND JURISDICTION CONTROLS

Users may not access or use the Services if doing so would violate Applicable Law or applicable sanctions, export-control, or geographic restrictions. Users may not use the Services on behalf of, or for the benefit of, a sanctioned or restricted person or entity.

SpeedyTurtle may use reasonable access controls, including IP- or location-based restrictions, and may suspend or terminate access when required by law or reasonably necessary to enforce the Terms.

Users may not conceal their location or use a VPN, proxy, Tor, location spoofing, or another method to evade a restriction described in the Terms.

6. PROHIBITED AND ILLICIT USE

Users may not use the Services to:

• violate Applicable Law or applicable sanctions;
• engage in fraud, market manipulation, money laundering, terrorist financing, or deceptive conduct;
• compromise accounts, Wallets, systems, protocols, or data;
• evade access controls or conceal prohibited activity;
• infringe the rights of SpeedyTurtle or any third party.

7. DISCRETIONARY RISK CONTROLS

Where reasonably necessary, SpeedyTurtle may:

• restrict or suspend access to the Services;
• request limited information;
• review relevant account, platform, IP, location, or public blockchain data;
• decline, withhold, or terminate Services or program rewards;
• cooperate with service providers or authorities as permitted or required by law.

These measures are risk-based and may vary by circumstance. They do not guarantee that SpeedyTurtle will detect, prevent, or investigate every prohibited activity.

8. LAW ENFORCEMENT AND LEGAL REQUESTS

SpeedyTurtle responds to subpoenas, court orders, and other lawful governmental requests to the extent required by law. Because SpeedyTurtle does not take beneficial ownership or custody of user Digital Assets, it generally cannot freeze, reverse, or seize those assets on a public blockchain.

9. USER RESPONSIBILITIES

Users are responsible for:

• controlling and securing their Wallets and recovery credentials;
• reviewing manual instructions and automated strategy settings;
• complying with laws and restrictions that apply to them;
• paying applicable taxes and fees;
• avoiding prohibited or illicit activity.

10. CHANGES TO THIS POLICY

SpeedyTurtle may update this Policy from time to time. Material revisions will be reflected in the “Last Updated” date. Continued use of the Services is subject to the version of this Policy then in effect and the change provisions in the Terms.

11. CONTACT

Compliance inquiries may be directed to:

SpeedyTurtle Labs, LLC
Email: support@speedyturtle.io