Anti-Money Laundering Website Policy

Last Updated: 1 May, 2024

Introduction

We are dedicated to preventing, detecting, and deterring individuals and entities involved in fraud, money laundering, and terrorist financing from utilizing our products and services. We recognize the importance of preventing and combating money laundering activities and emphasize our commitment through this Anti-Money Laundering Policy (the “AML Policy”).

AML Compliance Program

We have established an AML Program designed to comply with AML laws and regulations in the applicable jurisdictions we operate in. This AML Policy underscores our ongoing commitment to identifying and preventing money laundering and terrorism financing in connection with our services. Our AML Program includes:

• Designation of an AML Compliance Officer: Responsible for coordinating and monitoring the day-to-day compliance with the AML Program.

• AML Risk Assessments: Conducted at the program, customer, and product and services levels.

• Written Policies and Internal Controls: Designed to facilitate ongoing compliance with applicable AML laws and regulations.

• Customer Identification & Verification Procedures (KYC): Includes Enhanced Due Diligence (EDD) for high-risk customers, such as Politically Exposed Persons (PEPs).

• Card Verification: Procedures such as Payment Instrument Verification (PIV) or 3D Secure authentication.

• Transaction Monitoring & Ongoing Monitoring: Analyzing data and transactional patterns to detect suspicious activities.

• Money Laundering Reporting Officer (MLRO): Appointed with sufficient seniority to oversee compliance with relevant legislation, regulations, rules, and industry guidance.

• Risk Assessment and Management: A risk-based approach to combat money laundering and terrorist financing, balancing risk with the need to optimize financial growth opportunities.

• Record Keeping: Maintaining appropriate records for legally prescribed periods.

• Suspicious Activity Reporting: Reporting suspicious activity to relevant law enforcement authorities in all jurisdictions we operate.

• Sanctions Policy: Screening against sanctions lists from the United Nations, European Union, UK Treasury, and US Office of Foreign Assets Control (OFAC) in all jurisdictions we operate.

• Employee Due Diligence and Risk Awareness Training: Screening all employees, conducting additional background checks on entrusted employees, and providing ongoing training for all relevant employees.

We continually evaluate and update our policies, procedures, and technologies to address the evolving landscape of financial crimes, ensuring our staff is well-equipped to combat money laundering and other financial crimes.