ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING

In order to protect customer funds and ensure compliance with international standards, the Company takes all necessary measures to prevent and counter money laundering, terrorism financing and the proliferation of weapons of mass destruction (AML/CFT Policy).

Thus, the Company takes a firm stance on preventing all types of illegal activity. To fulfill these obligations, the Company is required to inform the competent authorities if there are grounds to suspect that the funds deposited by a customer into their account are connected with illegal activity or terrorism financing. The Company is also required to freeze such funds and take measures provided for by the rules of the AML/CFT Policy and applicable law.

The following terms are widely used in this field:

• Money laundering: The process of giving a legitimate appearance to illegally obtained income. This process is usually divided into three stages: placement, layering and integration.
• Placement: The process of placing illegal income into traditional financial institutions through deposits or other channels.
• Layering: The process of concealing the origin of funds obtained through crime using complex financial operations, such as converting cash into traveler's checks, money transfers, letters of credit, stocks, bonds or the purchase of assets.
• Integration: The use of seemingly legitimate operations to disguise illegal income, allowing the laundered funds to be distributed back to the criminal, integrating them into normal use.
• Suspicious activity: Activity carried out by a customer through an institution where there are indications that the persons involved in the transaction may be doing so for fraudulent or illegal purposes.

To prevent criminal capital from penetrating the state's economy, many countries combat money laundering and terrorism financing.

The Company applies internal laws and regulations, as well as special measures to assist international organizations in combating money laundering and terrorism financing around the world.

In addition to the above, in accordance with anti-money laundering legislation, we inform you that any transaction in an amount equal to or exceeding 10,000 US dollars (or the equivalent in your account currency) will be documented and reported to the relevant Anjouan regulatory authority.

By opening an account, you agree to assume the following obligations:

• You agree to comply with all applicable anti-money laundering and counter-terrorism financing laws and regulations, including the AML/CFT Policy.
• You confirm that you have no information or suspicion that the funds used to top up the account in the past, present or future are obtained from an illegal source, connected with the legalization of illegally obtained income or other illegal activity prohibited by applicable law or the instructions of international organizations.
• You agree to immediately provide any information that we deem necessary in accordance with applicable laws and regulatory requirements in the field of countering the legalization of illegally obtained funds.

The Company collects and stores a passport or other identity document of the customer, and also records all changes made to the account.

The Company monitors any suspicious activity on the customer's account, as well as operations carried out under special conditions.

The Company has the right at any time to block a customer if there are grounds to assume that this operation is related to money laundering and criminal activity. In accordance with international law, the Company is not obligated to inform the customer about their suspicious activity or to notify them of the transfer of information to the relevant authorities.

In accordance with internal AML/CFT procedures, the Company conducts initial and ongoing identity verification procedures depending on the risk level of each customer.

The Company will request the minimum information from you to confirm your identity.

The Company records and stores all data and documents, as well as the verification methods used and the results of the verification procedures.

The Company checks your personal data against the list of persons suspected of terrorism, compiled by authorized state and independent bodies. The minimum set of identification data includes: the customer's full name, date of birth, place of residence and the customer's contact details;

The sources of funds that you plan to deposit into your account.

To verify and confirm the authenticity of the specified data, the Company may request the following documents:

• a passport or identity card or another document equivalent to them, issued by national state authorities, which meets the following requirements: contains the full name, date of birth and a photograph of the document holder; the validity of the document does not expire within the next 3 months;
• recent utility bills or a bank statement (issued within the last 3 months) or other documents confirming the customer's address.

The Company may also request other additional information confirmed by relevant documents. In certain cases, the Company may require notarized copies of the customer's documents.

All personal data will be destroyed when it is no longer necessary for storage or as required by law.

This AML/CFT policy will be reviewed as necessary to ensure its compliance with the requirements of the Anjouan regulatory authorities and international standards.